Anti-bribery And Anti-corruption Policy

Unyielding integrity is one of the corporate values of Central Finance Company PLC (the “Company”), hence the Company has zero tolerance for any form of bribery and corruption. The purpose of this Anti-Bribery and Anti-Corruption Policy (“Policy”) is to set out the principles and guidelines for countering bribery and corruption and the management of bribery and corruption risk in the Company. Whilst doing so, the Company intends to achieve compliance with all applicable rules, directions, regulations, statutes and laws pertaining to anti-bribery and anti-corruption.

This Policy is intended to outline the Company’s risks related to bribery and corruptions and the responsibilities of parties mentioned herein. This Policy applies to;

i. All employees of the Company and its subsidiaries, including directors, fixed-term and temporary staff as well as the personnel provided by outsourced agencies on contractual basis, at all levels and grades (hereinafter collectively referred as the employees for the purposes of this Policy).

ii. Third Parties and Service Providers – to the extent of their declaration and undertaking pertaining to not engage in any bribery and corruption involvement with the business affairs of the Company.

Bribery – Is generally defined as improperly offering, promising, authorizing, giving, soliciting, requesting, receiving or agreeing to receive a benefit or gratification to any person or entity in order to influence a decision of the recipient in an improper manner or to induce improper performance from the recipient, all of which may result in a business, financial, or other kind of gain or advantage to the offerer.

Corruption – Is the abuse of entrusted position or power with the intention of offering, gaining, or receiving any gratification, benefit or reward for any value whilst performing or non-performing a task in relation to a person’s position or rank within an establishment.

i. Our Company is committed to ensuring compliance with all applicable anti-bribery and anti-corruption laws.
ii. Our Company is apolitical, hence would not make contributions/donations to any political party or any entity associated with political parties.
iii. Our Company considers unyielding integrity as a core value and committed to conducting business with integrity and transparency.
iv. Our Company does not condone bribery and any form of improper payments/dealings in the conduct of business.

This Policy should be read in conjunction with the other policies, key documents and guidelines of the Company including;

i. Policy Statement on Anti-Money Laundering Countering Terrorism Financing and Know Your Customer
ii. Code of Conduct
iii. Outsourcing Policy
iv. Complaints Handling Policy
v. Financial Consumer Protection Policy
vi. Whistle Blowing Policy

All employees shall not

i. offer, promise pay or accept any bribe, secret commission, kickback or other form of improper payment/gratification, in order to obtain any improper business/advantage for the company, for themselves or for others;

ii. provide or accept any benefit, gifts, hospitality or entertainment or other things of value which are contrary to this Policy;

iii. venture into or continue a business relationship/ outsourced arrangement with a third party, if such third party is incapable of meeting the required standards mentioned herein;

iv. engage in a corrupt practice, by action or omission, which includes misrepresentation or suppression of material facts, in order to mislead credit officers to grant financial accommodations to non-creditworthy customers or their proxies;

v. engage in obstructive practice by concealing, altering, falsifying any documents or any evidence material to an investigation or making false statements to auditors or inquiring officers;

vi. influence, abate or refrain another employee from performing official duties being influenced by any corrupt practice or threatened by disciplinary action;

vii. cause, omit or authorize any of the obligations mentioned herein or any other conduct which has a bearing on this Policy.

Any breaches or non-compliance of any provisions of this Policy will be considered as a gross misconduct due to zero tolerance of any form of bribery and corruption. Accordingly, strict adherence to the provisions of this Policy is required to mitigate both compliance and reputation risks.
Any violators, by their action or omission, would render themselves liable to disciplinary action, including suspension and dismissal from service.

i. Any employee who become aware or suspects violation of this Policy by another employee is obligated to report such violations
ii. Such reporting shall be in writing or by e-mail. In case of communication by e-mail, CF recommends that the subject of the e-mail be ‘CF Anti-Bribery’ for the purpose of ease of identification.
iii. Complainants are encouraged to report in writing as it would enable a clear understanding of the concerns raised.
iv. It is recommended that the complainant identifies himself/herself in the letter/email, but such complainant could remain anonymous as provided in the Whistle Blowing Policy of the Company.
v. Any employee who has a concern should first raise such concerns to the HOD of such employee. If an employee feels that the concern relates to a matter which cannot be adequately addressed by such HOD he or she may choose to make direct contact with the persons whose names appear below.
vi. The organization establish a confidential and secure reporting mechanism to facilitate the reporting of bribery concerns. Information shared through this mechanism will be treated with the utmost confidentiality.
vii. The organization will conduct a prompt and impartial investigation into all reported violations of the Anti-Bribery Policy. Investigations will be carried out by personnel who are independent of the reported incident and have the necessary expertise to conduct a thorough examination and appropriate corrective and preventive actions will be taken.
viii. Regular training and awareness programs will be conducted to educate employees on the importance of reporting bribery concerns and the procedures to follow for making such reports.

Mr. Ronald George                           Mr. Arjuna Gunaratne
GM Human Resources                      Managing Director
Central Finance Co PLC                    Central Finance Co PLC
No: 270, Vauxhall Street,                  No 270 Vauxhall Street,
Colombo 2.                                      Colombo 2.
Telephone: 0703-566899                 Telephone: 0706739789
E-mail: ronaldg@cf.lk                      E-mail: arjuna@cf.lk

This policy would be reviewed from time to time as and when it is required.