Specter Energy Business Ethics & AntiCorruption Policy and Procedure
Purpose
This policy outlines the ethical standards and anti-corruption practices required for all
employees, contractors, and business partners of Specter Energy to promote integrity,
transparency, and compliance with international standards.
Scope
This policy applies to all employees, officers, directors, contractors, third-party
representatives, agents, and business partners of Specter Energy globally.
Policy Statement
Specter Energy is dedicated to conducting its business ethically, transparently, and
responsibly. We are committed to fostering a culture of integrity and accountability in all
our operations. This policy aims to ensure that all employees and associated parties
adhere to the highest standards of ethical behavior and comply with all applicable anticorruption laws and regulations, including the United Nations Convention Against
Corruption (UNCAC) and the OECD Guidelines for Multinational Enterprises.
We believe that corruption undermines trust, damages reputations, and hampers
economic development. Therefore, Specter Energy prohibits all forms of corruption,
including bribery, facilitation payments, and conflicts of interest. We require all employees
to act with integrity, maintain confidentiality, and respect the rights and dignity of all
stakeholders.
Ethical Standards
Integrity and Honesty
•
All employees must act with integrity and honesty in all business dealings.
o
Conduct regular training sessions on ethical behavior.
o
Perform internal audits to ensure compliance.
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq
o
Foster an environment where ethical conduct is recognized and rewarded.
o
International Standards: UNCAC Articles 5, 8.
Respect and Fairness
•
All stakeholders must be treated with respect and fairness.
o
Establish a Diversity and Inclusion Committee.
o
Implement regular feedback mechanisms.
o
Enforce non-discrimination policies and equal opportunity practices.
o
International Standards: OECD Guidelines, Chapter IV.
Confidentiality
•
Employees must protect and properly manage all confidential information.
o
Sign confidentiality agreements.
o
Use secure IT systems and protocols.
o
Limit access to sensitive information on a need-to-know basis.
o
International Standards: ISO 27001 for Information Security Management.
Anti-Corruption Practices
Prohibition of Bribery and Corruption
•
No employee shall offer, give, solicit, or receive any form of bribe or kickback.
o
Mandatory anti-bribery training for all employees.
o
Enforce a zero-tolerance policy on bribery.
o
Monitor and audit financial transactions regularly.
o
International Standards: UNCAC Article 15, UK Bribery Act 2010.
Facilitation Payments
•
Facilitation payments are strictly prohibited.
o
Provide clear reporting channels for suspected facilitation payments.
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq
o
Conduct regular audits to identify and prevent such payments.
o
Educate employees on the risks and consequences of facilitation payments.
o
International Standards: FCPA (Foreign Corrupt Practices Act) guidelines.
Conflicts of Interest
•
Employees must avoid situations where personal interests conflict with the
interests of the company.
o
Require conflict of interest declaration forms from employees.
o
Implement regular disclosures and monitoring.
o
Address and resolve any identified conflicts promptly.
o
International Standards: OECD Guidelines, Chapter II.
Due Diligence
•
Conduct thorough due diligence on third-party business partners.
o
Establish comprehensive vetting processes.
o
Use due diligence software and tools.
o
Regularly review and update due diligence procedures.
o
International Standards: ISO 37001 for Anti-Bribery Management Systems.
Reporting and Compliance
Reporting Mechanism
•
Establish a confidential and anonymous reporting mechanism for employees to
report unethical behavior or suspected corruption.
o
Set up a whistleblower hotline and secure online reporting tools.
o
Ensure reports are handled confidentially and promptly.
o
Protect whistleblowers from retaliation.
o
International Standards: UNCAC Article 33.
Compliance and Monitoring
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq
•
Regularly monitor and review compliance with this policy.
o
Conduct internal audits and compliance checks.
o
Appoint compliance officers to oversee adherence to the policy.
o
Engage external reviewers for unbiased assessments.
o
International Standards: ISO 19600 for Compliance Management Systems.
Disciplinary Actions
•
Violation of this policy may result in disciplinary actions, including termination of
employment and legal action.
o
Establish clear disciplinary procedures.
o
Document and enforce disciplinary actions consistently.
o
Communicate the consequences of violations to all employees.
o
International Standards: UNCAC Article 30.
Training and Awareness
•
Conduct regular training on ethics and anti-corruption.
o
Organize annual training programs for all employees.
o
Develop e-learning modules and workshops.
o
Update training materials regularly to reflect current laws and best practices.
o
International Standards: OECD Guidelines, Chapter VII.
Review and Amendments
•
This policy will be reviewed periodically and updated as necessary to reflect
changes in laws and business practices.
o
Perform annual policy reviews.
o
Conduct stakeholder consultations to gather feedback.
o
Update the policy based on legal and industry developments.
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq
o
International Standards: Best practices from international compliance
frameworks.
Implementation and Responsibilities
Board of Directors
•
Oversee the implementation of this policy and ensure it is integrated into the
corporate culture.
o
Review and approve policy updates.
Management
•
Responsible for day-to-day implementation and enforcement of the policy.
o
Ensure that all employees are aware of and comply with the policy.
Employees
•
Must adhere to the policy and report any violations.
o
Participate in training programs and stay informed about policy updates.
Compliance Officer
•
Monitor compliance, conduct training, and handle reporting mechanisms.
o
Investigate reported violations and take appropriate action.
Procedures
Reporting a Violation
1. Establish Reporting Channels: Set up a confidential whistleblower hotline
available 24/7. Implement a secure online reporting tool accessible from any
device. Provide a physical drop-box for anonymous submissions.
2. Encourage Reporting: Regularly communicate the importance of reporting
unethical behavior. Assure employees that reports will be handled confidentially
and that whistleblowers will be protected from retaliation.
3. Receive and Acknowledge Reports: The Compliance Officer receives the report
and acknowledges receipt within 48 hours. A tracking number is provided to the
whistleblower for follow-up.
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq
4. Investigate Reports: A preliminary assessment is conducted to determine the
credibility and severity of the report. If warranted, a full investigation is initiated,
involving relevant departments and external experts if necessary.
5. Take Action: Based on the investigation findings, appropriate actions are taken,
which may include disciplinary measures, legal action, or policy changes. The
whistleblower is informed of the investigation outcome, maintaining confidentiality.
6. Document and Review: All reports and investigations are documented and
reviewed periodically to identify patterns and areas for improvement.
Conducting Due Diligence
1. Initial Vetting: Use a standardized due diligence questionnaire to gather
information on third-party business partners. Check for any red flags, such as past
involvement in corruption or unethical practices.
2. In-Depth Assessment: Perform a detailed background check using due diligence
software and external databases. Evaluate the partner’s compliance with ethical
standards, financial stability, and reputation.
3. Approval Process: Compile a due diligence report and present it to the
management for approval. Only partners who meet Specter Energy’s criteria are
approved and onboarded.
4. Ongoing Monitoring: Conduct regular reviews of third-party partners, updating due
diligence records as needed. Monitor for any changes in the partner’s status or
behavior that could pose a risk.
Training Programs
1. Annual Training: Organize mandatory annual training sessions for all employees,
covering ethics and anti-corruption policies. Use interactive methods, such as case
studies and role-playing, to enhance understanding.
2. E-Learning Modules: Develop e-learning modules accessible to all employees at
their convenience. Include quizzes and assessments to ensure comprehension.
3. Workshops and Seminars: Conduct periodic workshops and seminars with experts
on ethics and anti-corruption. Focus on real-life scenarios and practical application
of policies.
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq
4. Continuous Improvement: Regularly update training materials to reflect new laws,
best practices, and feedback from employees. Evaluate the effectiveness of training
programs through surveys and assessments.
Review and Update
1. Annual Review: The Compliance Officer and a designated review team perform an
annual review of the policy. Assess the policy’s effectiveness and alignment with
current laws and industry standards.
2. Stakeholder Consultation: Gather feedback from employees, business partners,
and other stakeholders through surveys and focus groups. Incorporate relevant
suggestions into policy updates.
Phone: +964 750 333 6933
+964 750 541 4494
Email: info@specter-energy.com
info@specter.iq
Address: Nisry Building, Floor 4, Office 12
KRO Street, Duhok 42001, Iraq