About LuxRelo
Anti-Bribery and Corruption Policy
LuxRelo values its reputation and maintains the highest ethical standards in the conduct of its business. This policy sets out what we expect from everyone who acts on our behalf.
Our Position
LuxRelo does not tolerate bribery or corruption in any form.
Our work brings us into daily contact with public administrations, employers, landlords, agencies and service providers, in Luxembourg and abroad. Our clients trust us to obtain results the right way. We never offer, give, request or accept an improper advantage to obtain or speed up a decision.
Who This Policy Applies To
This policy applies strictly to all employees, managers, agents, consultants, contractors and to any other person or organisation acting on LuxRelo's behalf, in every office, area and function.
What Bribery and Corruption Are
Bribery is offering, promising or giving a financial or other advantage to a person with the intention of inducing that person to act, or rewarding them for having acted, in a way that a reasonable person would consider improper. Corruption is any abuse of entrusted power for private gain; it includes, but is not limited to, bribery.
Bribes are not always a matter of handing over cash. Gifts, hospitality and entertainment can be bribes when they are intended to influence a decision.
What Is Prohibited
LuxRelo prohibits the offering, giving, solicitation or acceptance of any bribe or corrupt inducement, in cash or in any other form:
- to or from any person or company, wherever located, whether a public official or public body, or a private person or company;
- by any employee, manager, agent, consultant, contractor or other person or organisation acting on LuxRelo's behalf;
- in order to gain a commercial, contractual or regulatory advantage for LuxRelo in a way that is unethical, or to gain a personal advantage, financial or otherwise, for the individual or anyone connected with them.
What remains acceptable
This policy does not prohibit the following practices, provided they are appropriate, proportionate and properly recorded:
- normal hospitality;
- fast-tracking a process that is available to everyone on payment of an official fee;
- providing resources to help a person or body reach a decision more efficiently, for that purpose only.
Key Risk Areas
- Gifts, entertainment and hospitality
Acceptable within reasonable limits and when authorised by the Compliance Officer. Any gift or hospitality given or received above 100.00 EUR per person is reported to the Compliance Officer.
- Facilitation payments
Payments made to secure or speed up a routine action to which the payer is already entitled. LuxRelo never makes or tolerates them, including towards administrations, landlords or agencies.
- Reciprocal agreements
Any form of quid pro quo is never acceptable, unless it is a legitimate business arrangement, properly documented and approved by the Compliance Officer.
- Third parties
Agents, contractors and consultants act on LuxRelo's behalf. Due diligence is carried out before they are engaged, a clear contract is in place and every payment to them is authorised and recorded.
- Record keeping
Records can be used to conceal a bribe. Our controls keep every record accurate and transparent; the Compliance Officer is responsible for record keeping.
Penalties
Bribery and corruption are criminal offences under Luxembourg law, punishable by imprisonment and fines for the individuals involved, with consequences for the company as well. Beyond the legal penalties, a conviction would have severe reputational and financial consequences for LuxRelo and for the people concerned.
Reference: Code pénal, Legilux (official journal of the Grand Duchy of Luxembourg). This policy is an internal rule of conduct, not legal advice.
Responsibilities and Breaches
The prevention, detection and reporting of bribery or corruption are the responsibility of every manager and employee. Anyone who becomes aware of, or suspects, an activity or conduct, proposed or past, that could be a bribe or corrupt has a duty to report it to the Compliance Officer without delay.
It is not always simple to determine whether a course of action is appropriate. In case of doubt, the matter is referred to Stéphane Compain, LuxRelo's Compliance Officer, before acting.
LuxRelo investigates thoroughly any actual or suspected breach of this policy or of its spirit. Employees found to be in breach may be subject to disciplinary action, which may ultimately result in dismissal. Third parties in breach see their engagement terminated.
Review
This policy is reviewed at least once a year by the Compliance Officer to verify that it remains up to date, compliant and in effective operation. Records of the reviews are kept and the policy is amended as necessary.
Raise a Concern
Write to info@luxrelo.lu, for the attention of Stéphane Compain, Compliance Officer. Concerns raised in good faith are treated in confidence and never lead to reprisals.
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