Compliance

We Alliant Energy Solutions (BD) Ltd. takes Compliance very seriously and we strive to conduct our business in line of the following principles:

The purpose is to assist employees, officers and directors throughout the Company, and all of our business partners, in identifying anti-bribery and corruption-related issues and in understanding and complying with applicable anti-bribery and anti-corruption standards. This Policy is to be read in conjunction with the entirety of our anti-corruption compliance program policies and procedures. These policies and procedures include the Ethics Code, this Policy and the following supporting policies/procedures:

• Business Entertainment and Gifts Policy
• Procedure on Anti-Bribery and Corruption Due Diligence
• Supplier Code of Conduct.
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Commitment to Best Practices

Anti-Bribery and Corruption

All forms of bribery are prohibited at AESBD, whether conducted directly or indirectly through a third party, and whether involving Government Officials, private sector individuals, or private or state-owned companies. AESBD also prohibits facilitation payments.

AESBD promotes a culture of open and honest communication. The company’s Open Door Policy encourages everyone to ask questions and raise concerns. Questions and concerns can be reported through various channels, including anonymously through the AESBD Hotline. Compliance can be contacted directly by phone at +88 02 41080526-27 or by email at info@alliantenergybd.com.

Consult Local Law

This is meant to provide general principles and guidance with respect to anti-bribery and corruption-related matters. We always consult and follow the applicable local laws.

Guiding Principles

We Commit to the Following:

We will have zero tolerance for offering, promising, paying or accepting any corrupt payment, benefit or inducement to any person, whether a Government or Public Official or an employee or agent of a customer, supplier or competitor.

We will maintain accurate books and records, in accordance with internal Company financial controls and related procedures and policies. No undisclosed or unrecorded fund or asset may be established or maintained for any purpose. No director, officer or employee will participate in falsifying any accounting or other business record. Every director, officer or employee will respond fully and truthfully to any questions from the Company’s internal and/or independent auditors.

We will conduct reasonable anti-corruption due diligence in connection with acquisitions, the formation of joint ventures and the engagement of third parties. We will not proceed with any transaction or engagement until any concerns or issues relating to corruption have been fully and satisfactorily addressed.

We will strongly encourage reporting, without fear of retaliation, of any known or suspected bribery or corrupt conduct.

We will investigate all reports of known or suspected corrupt activity perpetrated by any individual, either employed or in a business relationship with the Company.

We Must Never:

• Make facilitation payments. Such payments are considered a form of corruption and are prohibited under the local laws of most countries and by the OECD Convention and the United Nations Convention Against Corruption. We must never offer a facilitation payment.
• Engage in corrupt activities or activities that could reasonably give the appearance of corruption. We attempt to avoid situations creating the appearance of impropriety, including with respect to business entertainment, gifts, conflicts of interest, hiring and donations.
• Engage in bribery. Company employees (including temporary and contract employees), officers and directors are prohibited from engaging, directly or indirectly, in bribery.
• Allow third parties, including service providers, agents, consultants, brokers or distributors, to engage in bribery or corruption on our behalf.
• Do business with other parties who are engaged in bribery or corruption.
• Take retaliatory action towards employees who, in good faith, report suspected violations of the Ethics Code or this Policy. Allegations made in bad faith, however, will not be tolerated.
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Gifts, Business Hospitability and Entertainment

Policy
Offering gifts, business and other hospitality is an ordinary part of doing business, but it is also an area with significant potential for corrupt conduct. It is the policy of the Company never to offer gifts, business entertainment, hospitality or other personal benefits for improper purposes or as a means to induce someone to act for the benefit of the Company. Moreover, particular care must be exercised with respect to Government or Public Officials. Very often, legal and legitimate hospitality can be interpreted as a bribe, and the difference is hard to define in the abstract.

Local Regulations
You must be aware that any general monetary threshold established by the Company may exceed what is legal in a particular jurisdiction. Therefore, you must always consult the local laws and regulations of the jurisdiction in which you are doing business.

Counsel & Whistle-blowing of ethical management

We receive report for improper work process, request of unlawful bribe, unfair contract with sub-contractor by our employees. Privacy of the reporter will be protected and not to be exposed during investigation. 

Reporting Channels:
E-Mail: haider@alliantenergybd.com
Mail: ABM Haideruzzaman, Priyo Prangon Tower,
Flat 12/25, Plot 19, Road 17 Banani Commercial Area, Dhaka-1213, Bangladesh
Phone Call: (+880) 17134-69521

Legal Adviser
The Legal Circle (Member LexMundi)