Business Practices

  • We hold all our Third Parties to the highest ethical standard. Our partners must conduct business ethically and must not engage in any type of fraud, waste, or abuse. We require our Third Parties to fully comply with all laws, rules, and regulations applicable to their country of operation and any country in which the services are rendered.

  • We encourage our Third Parties to institute effective management systems that utilize the best available practices to adhere to this Code and continuously improve their performance. This should include a process for the identification and proactive mitigation of risks associated with compliance with this Code; particularly, when as it relates to the services rendered, as well as a process for ongoing monitoring and review of risk controls, and prompt and accurate reporting of all incidents.

  • Third Parties should establish policies, standards and procedures to comply with applicable regulations and promote operational excellence through ethical behaviors. These policies, standards and procedures should be widely publicized to all employees and subcontractors.

     

    Third Parties should avoid any conflicts of interest or the appearance of a conflict of interest.  They shall       disclose all actual or potential conflicts of interest due to either business or relationships between the     third party, PALIG, customers, competitors or employees.

Marketing, Communications & Social Media

In the marketplace, advertising and social media are important. It enables us to learn from and share information with our stakeholders, as well as communicate with the public about our Company. These transmissions are permanent and easily transferable and can affect the reputations of PALIG and the Third Party alike. For this reason, Third Parties are prohibited from using PALIG’s name, logo or other reference unless given prior written authorization.

Likewise, Third Parties may not publish any marketing materials, press releases, or media interviews which reference PALIG, its members, or the work being completed together – without previous written approval.

For more information, please contact Corporate Marketing at corporatemarketing@palig.com.

Anti-Bribery and Anti-Corruption

We are committed to dealing legally and ethically with governments worldwide. The United States and many other countries have laws that prohibit bribery, kickbacks, and other improper payments.

No Third Party acting on behalf of PALIG may offer or provide bribes or other improper benefits in order to obtain business or an unfair advantage. A bribe is defined as directly or indirectly offering anything of value (e.g., gifts, money, or promises) to influence or induce action, or to secure an improper advantage.

The Foreign Corrupt Practices Act (FCPA) and other United States laws prohibit payment of any money or anything of value to a foreign official, foreign political party (or official thereof), or any candidate for foreign political office for the purposes of obtaining, retaining, or directing of business. We expect all Third Parties to strictly abide by these laws and immediately report to PALIG any instances of non-compliance.

Anti-Money Laundering

Money laundering is defined as the process of converting illegal proceeds so that funds are made to appear legitimate, and it is not limited to cash transactions. Complex commercial transactions may hide financing for criminal activity such as terrorism, illegal narcotics trade, bribery, and fraud. Involvement in such activities undermines our integrity, damages our reputation, and can expose PALIG and individuals involved to severe sanctions.

We require our Third Parties to prohibit knowingly engaging in transactions that facilitate money laundering or result in unlawful diversion of funds. Third Parties must take affirmative steps to detect and prevent unacceptable or illegal forms of payment and financial transactions. Anti-money laundering laws of the United States and other countries and international organizations, require transparency of payments and the identity of all parties to transactions.

We are committed to full compliance with applicable anti-money laundering regulations and will conduct business only with reputable customers and service providers involved in legitimate business activities and transactions.

  • We believe in free and open competition. In addition, in most of the countries where we operate, strict laws are in force similar to antitrust laws in the United States which prohibit collusive or unfair business behavior that restricts free competition. Third Parties should comply with all applicable antitrust or competition laws.

     

    Few circumstances are allowed by law to enter agreements with competitors in regard to price fixing, bid rigging, terms of sale, production output, or to divide markets or customers. In addition, attempts to discriminate illegally (i.e., non-actuarially justified) regarding prices or terms of sale among our customers, or to otherwise restrict the freedom of our customers to compete, may sometimes be illegal. Legal issues may also arise if we refuse to deal with certain customers or competitors.

  • During the business relationship, Third Parties and their associates may come into possession of inside information. Unauthorized use could result in a violation of insider trading laws. In general, these laws prohibit the buying or selling of stock in any public company when the individual has material information that has not been released to the public.

     

    Third Parties must refrain from communicating nonpublic information to anyone who might use it to buy or sell securities and must refrain from doing so themselves. “Tipping” others in this way may violate laws and can result in penalties to all parties involved, including the Third Party.

  • We require compliance with all United States federal import and export laws and regulations. These laws restrict transfers, exports, and sales of products or technical data from the United States to certain prescribed countries and persons as well as re-export of certain such items from one non-U.S. location to another. Many countries in which we operate have similar laws and regulations. Third Parties in connection with PALIG activities are responsible for knowing and abiding by these laws.

Gifts and Entertainment

When performing services for or on behalf of PALIG, we require that no gifts, business courtesies, or entertainment should be accepted or provided by a Third Party if it will obligate, or appears to obligate, the receiver. Even if acceptable by local custom, the giving or accepting of bribes, inappropriate, lavish, repeated gifts, or other benefits is always prohibited.

Similarly, requesting or soliciting gifts or services, as well as requesting contributions from vendors, suppliers or other Third Parties is prohibited. Under no circumstance should accepting or providing entertainment (including but not limited to event tickets, recreation, and beverages) influence or appear to influence a decision.

Our Third Parties are expected to always exercise good business judgement when deciding to accept or provide gifts, business courtesies or entertainment in connection with performing services on behalf of PALIG.

Subcontractors

If a Third Party works with other parties such as subcontractors in conducting its business with PALIG, the Third Party is responsible for informing PALIG of the subcontractors with whom it works – as required under the appropriate agreement. All provisions of this Code are applicable to subcontractors used by a Third Party in connection with PALIG business.