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