Anti-Bribery & Anti-corruption

FLE and its Business Partners, including all directors, officers, and employees and anyone acting on their behalf, must always respect and comply with criminal law, particularly in regards to corruption and bribery, whether in the private sector or towards public officials, which is penalized. This includes all laws, rules, and regulations of any jurisdiction applicable to FLE or Business Partners from time to time concerning or relating to bribery or corruption, including, without limitation, the United States "Foreign Corrupt Practices Act of 1977", the UK "Bribery act 2010", the China "Unfair competition prevention Act", and the Japan "Unfair Competition Prevention Act" as amended, and the rules and regulations thereunder.

Directors, officers, and employees must not demand, allow themselves to be promised or accept a Thing of Value for themselves or for a third person in return for the fact that they provide or will in the future provide improper advantages. Inversely, the offer, promise, or granting of an improper Thing of Value is not allowed and will not be tolerated. This especially applies to public officials or persons entrusted with special public service functions in view of their official function, as well as private individuals (if they exceptionally do not have a legally effective permission of their supervisor).

A Thing of Value refers to any kind of benefit, including, but not limited to, cash and cash equivalents, such as gift cards, transportation cards, vouchers, coupons, loans, frequent flyer miles, gifts, meals, travel, and other hospitalities, compensation for services, political contributions, donations, and sponsorships, employment and business opportunities, and internships (paid or unpaid), or other favours or offers thereof.

Any payments made on behalf of FLE or in connection with any work performed for it must be made in accordance with the Anti-Corruption Laws. Business Partners must maintain a record of such payments that contains reasonable detail and accurately and fairly reflect the purpose and amount of the payments.

At FLE, we believe in conducting business with the utmost integrity and ethics. We strictly prohibit any form of bribery, including promises, offers, permissions, provisions, or acceptance of bribes, to obtain or retain business, or gain unjust or improper benefits, such as offering improper benefits to anti-social forces or engaging in insider trading.

To ensure that we remain compliant with laws and regulations on bribery, we maintain accurate accounting records and implement procedures to monitor and prevent any potential acts of bribery. We also conduct regular education and training sessions for our employees to ensure that they understand the importance of complying with anti-bribery laws and regulations.

By upholding these standards, we strive to maintain a reputation of trust and reliability in the industry and build long-lasting relationships with our stakeholders based on mutual respect and ethical business practices.