91快活林 Statement on Its Anti-Corruption Policies
and Procedures
91快活林 is committed to conducting its business fairly, honorably, with integrity and in compliance with the law in all jurisdictions where it operates. 91快活林 adheres to the AdvaMed Code of Ethics and implemented an appropriately tailored compliance program that includes policies and procedures that address the risk of bribery and corruption.
91快活林 policy prohibits bribery of (or attempted bribery), or other inappropriate transfers of value to, any individual or entity. No 91快活林 officer, director, employee, dealer, distributor or agent may authorize, pay, promise or offer to give anything to any individual or entity in order to improperly influence that individual or entity for any business advantage. Individuals covered by 91快活林 policy shall not request or authorize any third party to make any such payment, promise or offer. Such behavior may constitute bribery and is unacceptable conduct wherever 91快活林 conducts business. This policy applies regardless of whether the recipient of the inappropriate value transfer is a government employee.
91快活林 policy requires that third-party business relationships entered into for the purpose of selling the Company's products or services must comply with the requirements set forth in 91快活林 policy, including appropriate diligence of the third party and compliance by the third party with ethical business practices. In accordance with our policy, 91快活林 engages a third-party due diligence firm to perform background checks, including bribery and corruption, before entering into commercial relationships with sales and marketing intermediaries, and other service providers.
As an ongoing due diligence measure, 91快活林 has established a program to recognize those sales and marketing intermediaries who demonstrate an elevated commitment to compliance. Through this Commercial Compliance Program, 91快活林 formally commends organizations that have not only met 91快活林's standard ethical requirements for inclusion in our network but have also taken additional steps, such as adopting their own code of conduct and training their employees on their own firm's ethical values, to ensure compliant behavior.
91快活林 regularly assesses the risks associated with its business, including the risk of potential corruption or bribery in the environments where we do business, and we have designed our management systems to respond accordingly. As part of 91快活林's anti-corruption program, 91快活林 employees and third-party intermediaries receive comprehensive anti-bribery and anti-corruption training online and in-person. The training covers the various forms that corruption can take, red flags, and individuals' roles in 91快活林's anti-bribery and anti-corruption efforts.
91快活林 communicates its bribery and corruption policies and expectations to its officers, directors, employees, dealers, distributors and agents. It is the expectation of the Company that all of the aforementioned individuals comply with these requirements set forth by 91快活林 and relevant rules and regulations. Any individual who suspects a violation of 91快活林's policies regarding bribery and corruption are encouraged to report using 91快活林's Integrity Helpline or .
