Preventing Money Laundering
Managing Gifts and Entertainment Responsibly
Ethos recognizes the importance of protecting the integrity of the global financial system from money laundering, terrorist financing, and other financial crimes. The company will comply with all applicable governmental requirements that have been designed to prohibit and prevent both actual and potential money laundering, as well as other activities that facilitate money laundering, the funding of terrorist activity, and other financial crime. Ethos will not knowingly deal with proceeds from unlawful activity or that support terrorist activities. Ethos will not deal with individual’s, entities, or restricted countries designated by the U.S Department of Treasury Office of Foreign Assets Control (“OFAC'') and similar applicable sanctions regulations in other countries where the company operates.
At Ethos, we understand that giving and receiving gifts or entertainment can be a common part of doing business. However, it's important to ensure that these exchanges don't create a conflict of interest or suggest anything improper. That's why we expect all employees to follow our guidelines for managing gifts and entertainment, and to avoid any actions that could be perceived as unethical or give us an unfair advantage. We also have guidelines for political contributions and entertaining politicians and government officials. For more information, please review our policies on gifts and entertainment.
Anti-Money- Laundering and Trade & Economic Sanctions Policy.
Gifts and Entertainment Disclosure Form
Anti-Corruption and Bribery Policy
Refusing to take bribes or pay kickbacks Ethos has a zero-tolerance policy towards bribery and corruption.All employees and representatives are responsible for understanding and complying with our policies, the Foreign Corrupt Practices Act, and applicable local anti-bribery and anti-corruption laws. We are committed to conducting our business with integrity and refuse to take or offer bribes or kickbacks.
Best Practices
How to Politely Decline a Gift "Thank you for the gesture, but as part of our commitment to an ethical and transparent RFP process, we are not permitted to accept gifts or hospitality. We appreciate your understanding."
Follow internal rules on gift acceptance and procurement ethics.
When involved in a Request for Proposal (RFP) process or any vendor search - not accepting gifts or favors from vendors involved in the process is critical for maintaining fairness, transparency, and compliance with ethical expectations.
If you're unsure what to do, err on the side of caution and seek guidance.
Should an offer of a gift be made, notify Compliance@getethos.com or report the outreach through AllVoices
I am hiring a vendor to work for Ethos, and they want a flat fee for their services. Do I still need an itemized invoice?
Yes, even for fixed-rate services, it is essential to obtain an itemized invoice. This helps us understand and account for how our money is being spent, ensuring transparency and proper financial management.
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