Anti-Corruption / Anti-Bribery Policy

The Board of Directors of Labay/Summers International, Inc., requires management and staff of our company and all Labay/Summers vendor companies to be fully aware of the anti-corruption and anti-bribery policy of Labay/Summers International, Inc., and to remain in full compliance at all times.

The Board of Directors of Labay/Summers International, Inc., requires all management and staff of our company to comply with a very strict anti-corruption and anti-bribery policy in all business activities as well as general conduct. To even suggest or hint at any act of bribery would be considered to be in violation of the Labay/Summers anti-corruption and anti-bribery policy.

Engaging in such illegal activities can lead to substantial legal risks in connection with the laws of the United States and most countries throughout the world. Violations of anti-corruption and anti-bribery laws can lead to substantial monetary fines for both companies and individuals as well as possible imprisonment for individuals.

The enforcement of corruption and bribery laws in many countries is increasingly stringent and often include activities undertaken by a company through employees as well as third parties acting on behalf of a company within two or more international jurisdictions.

Bribery and / or corruption is frequently defined as the offering, promising, giving, accepting or soliciting of an advantage or other form of compensation as an inducement for any action which is illegal under any national law(s) or international law(s) and may be a breach of trust.

    The most common forms of corruption or bribery may originate from one or more of the following:

  • A payment or payments to one or more employees of a company or their relatives or a third party with said compensation designed to secure an advantage in business transactions;
  • One or more political contributions initiated to ensure an advantage in business transactions;
  • Any charitable sponsorship utilized to secure an advantage in business transactions;
  • The facilitation of payments, kickbacks or other forms of compensation to secure or accelerate necessary or routine business actions with government officials, clients, vendors or any other parties;
  • Any form of gift, hospitality, entertainment or other forms of payment or compensation as may be initiated to secure an advantage in business transactions.

The corporate conduct of Labay/Summers International, Inc., is firmly based on a policy of performing and acting in a fully legal and responsible manner with integrity in all matters.

That policy extends to all Labay/Summers client companies and all Labay/Summers vendor companies relative to all types of business activities with a special reference to implementing and observing anti-corruption and anti-bribery policies.

Scope

The anti-corruption and anti-bribery policy of Labay/Summers International, Inc., applies to all Labay/Summers employees, related personnel and third parties acting on behalf of Labay/Summers and extends to all business activities in all legal jurisdictions where Labay/Summers operates or is otherwise represented. Any violation of this policy by an employee of Labay/Summers International, Inc., shall result in automatic termination upon discovery.

Policy

Labay/Summers International, Inc., does not engage in any degree of corruption or bribery..

Individually, the management and staff of Labay/Summers International, Inc., does not engage in corruption or bribery and the failure to comply with the policy shall result in employment termination.

Labay/Summers International, Inc., functions as a Customs Broker and Freight Forwarder with the responsibility of handling logistics requirements on a worldwide basis. The responsibility includes securing corporate clients and vendors with firm anti-corruption and anti-bribery policies applicable to the conduct of such clients and vendors as well as the management and employees of the clients and vendors.

Responsibilities

The Board of Directors of Labay/Summers International, Inc., is responsible for establishing and maintaining an anti-corruption and anti-bribery policy applicable to the management and staff of Labay/Summers International, Inc.

The Board of Directors of Labay/Summers International, Inc., shall have the responsibility of reviewing the anti-corruption and anti-bribery policy on an annual basis to ensure said policy meets all ethical and legal requirements of all governmental jurisdictions on a worldwide basis.

Compliance

Compliance with the anti-corruption and anti-bribery policy of Labay/Summers is mandatory for all management and staff of Labay/Summers in all matters involving transactions with any third parties as may be involved with Labay/Summers clients and / or Labay/Summers vendors.

Compliance with the anti-corruption and anti-bribery policy of Labay/Summers is mandatory for all vendors of Labay/Summers, whether performing a service or services for Labay/Summers on a direct basis or through a third party.

The Board of Directors of Labay/Summers International, Inc., shall review and modify the anti-corruption and anti-bribery policy of Labay/Summers at any point necessary to ensure full compliance with all local, national and international laws as may be introduced, implemented and enforced relative to corruption and bribery