ANTI-BRIBERY AND CORRUPTION POLICY
Zero tolerance of bribery and corruption
“Matrix I.T. Ltd. and its subsidiaries (the “Company”) is the leading data technology services company in Israel. The Company has thousands of employees which provide services to hundreds of clients in Israel and abroad.
In light of its leading role in its field, the Company aspires to uphold a proper commercial culture for its employees, managers and office holders in filling their roles at the Company and to implement the Company’s core values as an integral part of its commercial activities, this includes the Company being committed to fight against bribery and corruption.
The Company’s management therefore decided to implement a zero-tolerance policy against bribery and corruption in order to ensure that the Company operates in accordance with the legislation relevant to preventing bribery and corruption, everywhere we operate, both in Israel and around the world.
For this purpose the Company adopted a comprehensive enforcement plan for the prevention of bribery and corruption, whose primary principles are detailed below.
We are confident that all of the Company’s employees, managers and commercial partners will do everything required in order to implement the Company’s directives and the enforcement plan for the prevention of bribery and corruption, and expect such to be done.”
The main principles of the Company’s zero tolerance of bribery and corruption policy include:
- First and foremost, the Company, including all of its employees, commercial partners and anyone working on its behalf, shall not offer, give or receive bribes, benefits or any other illegal incentive for any purpose, as part of its operating activities.
- The Company shall implement all the measures available to it against persons who contravene the foregoing.
- The Company and anyone acting on its behalf shall comply with the provisions of applicable law, relevant statute and regulations pertaining to the prevention of bribery and corruption.
- The Company shall not knowingly have a commercial engagement if it involves giving, offering or receiving bribery or other illegal incentives.
- The Company shall not have a commercial relationship with any person who contravenes its policy of zero tolerance against bribery and corruption.
- The Company shall strictly enforce the policy on its employees, affiliate commercial parties and its relevant commercial partners.
The Company’s commitment to preventing acts of bribery and corruption led to the Company adopting an enforcement plan for the prevention of bribery and corruption which was approved by the Company’s board of directors. The Company is constantly working to implement the plan with all the relevant parties.
The adoption of the Company’s policy on zero tolerance against bribery and corruption and the enforcement plan reflects the Company’s commitment to the prevention of bribery and corruption and gives the Company’s employees tools to identify, deal with and prevent acts of bribery and corruption.
Due diligence
Among other things, the enforcement plan for the prevention of bribery and corruption stipulates that due diligence is required to be performed prior to entering relevant engagements, as needed, and according to the level of risk.
Commercial partners engaging the Company are required to confirm that they are familiar with the Company’s zero tolerance on bribery and corruption policy and that they understand that they are required, and expected, to only act in accordance with the provisions of applicable law.
Business entertainment and gifts
The Company has adopted a procedure for business entertainment and gifts which is an integral part of the enforcement plan. This procedure defines the rules for business entertainment and for giving and receiving gifts (including limiting the approved costs for gifts), and, inter alia, stipulates that when working with a public official it is necessary to ensure that the granting of a fit and/or business entertainment, irrespective of the value, will not bias or impact the recipient’s discretion.
Donations
In light of the fact that a donation may be perceived as bribery of a public official, the Company has established that no direct or indirect donation or other gift is to be made to a not-for-profit charity in favor of and/or at the request of a public official. An examination is to be performed to ensure that the recipient of the donation is not related in any manner to public officials prior to making any donation.
Appointment of designated personnel
Designated personnel have been appointed for the implementation of the Company’s policy on the prevention of bribery and corruption. These personnel serve as the enforcement officers in the various commercial units. Their role is to advance, respond to questions, assist and implement the Company’s policy.
Report on deficiencies and whistleblower protection
As part of the Company’s activity to prevent bribery, the Company has adopted a high standard with protecting bribery and corruption whistleblowers. It has committed to implement effective measures to protect Company employees who expose bribery and corruption.
