Compliance Policy

Privacy, Anti-Bribery, Anti-Corruption and Anti-Trust

At Ocean our goal is to demonstrate the highest level of ethics and integrity in all our dealings with our customers, vendors and suppliers, competitors, and colleagues. This is a corporate priority and a shared responsibility for all our colleagues as each one of our actions and decisions affect our company and its reputation.

As laid out in our Social Responsibility Policy / Code of Conduct, colleagues are expected to act honestly, adhere to a strict Privacy Policy and comply with the laws and regulations governing our business, including anti-bribery and corruption, and demonstrate the highest level of ethics and integrity in all our dealings.

Both the Anti-Bribery and Corruption Charter and Anti-Trust Charter further expand upon the provisions outlined in our Social Responsibility Policy / Code of Conduct Policy and reinforce our long-standing commitment to integrity in business and our zero-tolerance approach to bribery and corruption. Each provides additional guidance as to what constitutes bribery and corruption and provides specific examples to help our colleagues, vendors and suppliers identify what actions are to be avoided.

What does this mean?

  • We will never engage in any form of bribery, directly or through a third-party.
  • We will never offer or make improper payments, or authorize improper payments to any individual, including local or foreign officials anywhere in the world.
  • We will never attempt to induce an individual, or a local or foreign official to act illegally or improperly.
  • We will never offer or accept anything of value (money, gifts, commissions, etc.) in connection with the procurement of business or the awarding of a contract.
  • We will never offer or give any gift or token of hospitality to any public employee, government official or representative if there is any implication for a return favor.
  • We will never accept any gift from any business partner if there is any suggestion that a return favor will be expected or implied.
  • We will never facilitate payments to obtain a level of service which one would not normally be entitled to.
  • We will never disregard or fail to report any indication of improper payments to the appropriate authorities.
  • We will never induce or assist another individual to break any applicable law or regulation.

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