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Anti-Corruption Policy

MOVE EN CONNECT COMPANY LIMITED

ANTI-CORRUPTION POLICY
Effective Date: 5 June 2025

Version: 1.0

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1. POLICY STATEMENT

Move En Connect has zero tolerance for bribery, corruption, or unethical conduct in any form. All employees, directors, contractors, agents, suppliers, and joint venture partners must adhere to this policy without exception. Violations will result in disciplinary action, contract termination, and legal prosecution.

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2. SCOPE

Applies to all activities globally, including:

  • Business operations: Freight forwarding, warehousing, customs clearance, procurement

  • Interactions: Clients, government officials, suppliers, subcontractors

  • Jurisdictions: Complies with the UK Bribery Act, U.S. FCPA, and local anti-corruption laws

 

3. PROHIBITED CONDUCT

3.1 Bribery

  • Offering, giving, receiving, or soliciting anything of value (cash, gifts, favors, kickbacks) to influence decisions.

  • Example: Paying a customs official to bypass inspections.

3.2 Facilitation Payments

  • Small bribes to expedite routine government services (e.g., port clearance, permits) are strictly prohibited.

3.3 Conflicts of Interest

  • Disclose personal/family ties to suppliers, clients, or competitors using the Conflict of Interest Disclosure Form.

3.4 Kickbacks & Secret Commissions

  • Undisclosed payments in exchange for business advantages.

 

4. RISK-BASED DUE DILIGENCE

Third-Party Vetting

Risk Level         Requirements

High-Risk          Full audit + background checks (e.g., customs brokers,

                           new market agents)

Medium-Risk    License verification + reference checks (e.g., freight forwarders)

Low-Risk            Sanctions screening (e.g., routine suppliers)

 

Tools: World Bank debarment lists, INTERPOL databases, AI-driven screening platforms.

  

5. GIFTS & HOSPITALITY

Type                         Limit (USD)                

Gifts                          ≤$50                          

Entertainment        ≤$100 /person        

Travel                       Prohibited               

 

Rules:

  • Never offered during tenders/contract negotiations

  • Must be transparently recorded in the Gift Register

 

6. RED FLAGS FOR LOGISTICS OPERATIONS

Watch for:

  • Invoices from shell companies or high-risk jurisdictions

  • Unjustified premium pricing for "urgent" shipments

  • Requests for cash payments or undisclosed subcontractors

  • Unusual speed/regulatory waivers at ports/borders

 

7. REPORTING & PROTECTION

  • Hotline: 24/7 anonymous reporting via [email/phone/portal] managed by [Independent Third Party].

  • Non-Retaliation: Whistleblowers are protected under the Whistleblower Protection Act.

  • Investigation: Led by Compliance Officer + external legal counsel within 14 days.

 

8. TRAINING & COMPLIANCE

  • Mandatory Training: Annual e-learning + scenario-based workshops for high-risk roles (procurement, customs teams).

  • Certification: Employees sign Anti-Corruption Commitment annually.

  • Audits: Quarterly surprise audits of high-risk transactions.

 

9. DISCIPLINARY ACTION

Violations may result in:

  • Termination of employment/contracts

  • Recovery of losses

  • Criminal referral

  • Blacklisting of involved third parties

  

10. GOVERNANCE

  • Policy Owner: Chief Compliance Officer

  • Review: Annual review by Board Audit Committee

  • Related Documents:

    • Procurement Anti-Corruption Guidelines

    • Supplier Code of Conduct

    • Financial Delegation Authority Policy

 

APPROVED BY:

Samart Panta

Managing Director

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