Ethical Business Conduct and Anti-Corruption Policy

Purpose and scope

This policy sets the standard of integrity expected of everyone who works for or represents FourSight Technologies Inc., including employees, contractors, subcontractors and agents.

Bribery and corruption

We never offer, give, request or accept bribes, kickbacks or any improper advantage, directly or through others. We comply with the Criminal Code and the Corruption of Foreign Public Officials Act. Facilitation payments are not permitted.

Gifts and hospitality

We do not offer gifts, hospitality or other benefits to public officials or client staff involved in a procurement while it is under way. Outside of a procurement, any business courtesy must be modest, infrequent, transparent and permitted by the recipient’s own rules.

Conflicts of interest

Team members must disclose any personal, financial or family interest that could influence, or appear to influence, their work for a client or a bid. We disclose relevant conflicts to clients and procurement authorities and manage or decline the work where needed.

Fair competition and procurement integrity

• We prepare every bid independently. We do not engage in bid-rigging, price-fixing or any other conduct prohibited by the Competition Act.
• We comply with the Government of Canada Code of Conduct for Procurement and the Ineligibility and Suspension Policy, and with the procurement rules of every public body we bid to.
• We do not seek or use confidential procurement information we are not entitled to, and we respect communication blackout periods.
• Any lobbying is carried out in compliance with applicable lobbying legislation.

Accurate records and representations

Our bids, invoices, timesheets and records are complete and accurate. We describe our experience, qualifications and resources truthfully.

Subcontractors

We expect subcontractors and agents acting for us to meet the standards in this policy and we include them in our agreements.

Consequences

Breaches of this policy may lead to disciplinary action, up to and including termination of employment or contract, and may be reported to the appropriate authorities.

Raising a concern

Anyone, including employees, contractors, clients and suppliers, can raise a concern about this policy by emailing [email protected] with “Confidential” in the subject line. Concerns are reviewed by the Lead Partner, handled confidentially to the extent possible, and never lead to retaliation against anyone raising an issue in good faith.

Related policies

See all of our policies on the Public sector page, including our Privacy Policy.