At Structure Tone, we act with honesty and integrity in our interactions with clients, business partners, and each other. Our efforts to obtain work and our interactions with government officials follow the highest ethical standards.
Structure Tone’s multi-dimensional, global Anti-Corruption program is designed to ensure that we operate according to the Company’s core values of integrity, collaboration, and transparency. Among other elements, the Program includes a comprehensive suite of written policies and procedures (including our Anti-Corruption Manual), a full curriculum of geographic-specific anti-corruption training, third-party due diligence, and internal compliance and anti-fraud controls.
The Anti-Corruption Manual applies to all Structure Tone employees and to members of the board of directors, agents, consultants, contracted labor and others when they are acting for or on behalf of Structure Tone. The manual also applies to the company’s vendors, subcontractors, suppliers and other business partners. We will only work with companies that uphold our values.
Key principles include:
- Strictly following all anti-bribery laws, including the FCPA, the U.K. Bribery Act, any laws enacted to comply with the UN Convention Against Corruption and the OECD Convention on Combating Bribery of Foreign Officials
- Promoting a marketplace in which decisions are based on ability, quality, and merit
- Diligently monitoring third parties to ensure that they are operating in an ethical and legally compliant fashion
- Speaking up and alerting management or the Compliance Department if something seems improper
- Maintaining accurate and complete records and documentation of all work performed
- Vigilantly monitoring financial transactions to ensure funds are expended according to client wishes and in a legally compliant fashion
- Only participating in reasonable and responsible corporate hospitality and business development, and ensuring that business decisions are based on appropriate criteria
Structure Tone wants all of its clients and stakeholders to assess and award us business solely on the quality of the services we provide. We hold our subcontractors, suppliers, and other business partners to the same standard.
We avoid providing gifts or entertainment to clients or potential clients, or receiving gifts or entertainment from business partners or potential business partners, when doing so would improperly influence a business decision.
Structure Tone permits employees to receive or provide gifts, meals, or entertainment (“Corporate Hospitality”) as an accepted aspect of building business relationships according to the following general guidelines:
- Corporate Hospitality must be reasonable and proportionate given the business relationship
- Corporate Hospitality may never be given or received when doing so may improperly influence, or appear to improperly influence, the business decisions of an involved party
- Employees may never provide or receive Corporate Hospitality as part of a quid pro quo (offered for something in return) or to obtain an improper advantage
- Cash or cash equivalents, include gift cards or gift certificates, are never permitted
- A Structure Tone employee must be present during a meal or entertainment. Otherwise, it is considered a gift and must satisfy the requirements of gift giving/receiving
- Because gift giving and receiving raises unique anti-corruption concerns, in addition to the requirements above, gifts may not exceed a fair market value of $100 without specific authorization