General Guidelines
• No payment or gift of any kind may be made promised or offered to a government ministry, Diamond Company, customers, etc. • Paying excessive travel and entertainment expenses on behalf of any diamond institution or government ministry to obtain or maintain business can be considered bribes. • An improper business advantage includes bribes to maintain your existing business operations. • Payments or gifts made to obtain or maintain business are forbidden. • Payments to an intermediary can be considered bribes. If an intermediary promises to have special connections and requires a high fee for his services and he bribes an official in order to secure business for you, that bribe can be imputed to you. "M.I.D. House of Diamonds" policy is to run a thorough background check on all intermediaries and have the Division President of Finance sign off on any payments to the intermediary. Payments to an intermediary may never be made in cash or case of an exceptional decision made by the Division President of Finance. • "Facilitation Payments" – this kind of payment is unacceptable in our company and is a violation of the company policy. "M.I.D. House of Diamonds" policy is that all facilitation payments must be thoroughly checked and approved by the Division President of Finance before the payment is made. • Accurate books and records must be kept, and falsified records to conceal a bribe are not allowed. For example, false cash payments invoices, false invoices, etc. These actions would violate these policy recordkeeping requirements, whether or not they also involved an attempt to obtain or maintain business.
Accepting gifts and hospitality
The acceptance of all gifts or hospitality must be approved and supervised by the management. Employees should refuse to accept gifts or hospitality that could influence or appear to influence decisions they make on behalf of the Company. The acceptance of small gifts such as flowers, and/or casual hospitality such as business lunches or tickets to events, is acceptable within reasonable bounds as long as it is a normal and appropriate expression of business courtesy. More substantial physical gifts such as wines, food hampers, etc. should be accepted courteously and passed on to the management. If there is any doubt about the propriety of accepting a gift or hospitality it should be refused. Travel and overnight accommodations should not be accepted - these are not considered entertainment that is reasonable in value and any such business-related expenses for our employees should be paid by the management.
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