Prohibited conduct
- Cash, kickbacks, secret commissions, hidden rebates or disguised fees
- Excessive or inappropriate gifts, travel, meals or entertainment
- Sham consulting, marketing, brokerage or commission arrangements
- Jobs, favours, donations or sponsorships used to influence decisions
- Improper payments through agents, customs representatives, relatives or other intermediaries
- Facilitation payments except where an immediate threat to health or safety requires action and prompt reporting
Third parties and records
Agents and intermediaries require proportionate due diligence, a legitimate scope, reasonable compensation, written terms and accurate records. No off-book account, false description or unsupported invoice is permitted.
Reporting
Requests or suspected violations must be refused and reported promptly to compliance@serica.global or speakup@serica.global. Good-faith reporting is protected from retaliation.