Financial Crime Statement

ANTI-BRIBERY & CORRUPTION

Linxia Ltd (“Linxia”), as a company operating within the Harel Mallac Group, has a zero-tolerance stance on bribery or corruption, be it directly or through intermediaries. We do not, under any circumstances, give, offer or receive a bribe or other improper advantage for business or financial gain. We refrain from engaging in business on behalf of the Harel Mallac Group, where we - or our immediate relatives – would obtain or appear to obtain a personal advantage. Linxia also undertakes to avoid dealing with business entities known or reasonably suspected to be involved in corruption.

As proud distributors of international brands, Linxia is subject to the provisions of local anti-bribery and corruption laws and is indirectly subject to the provisions of the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977 which have extra-territorial effect globally. We are, therefore, committed to maintaining the highest levels of legal and ethical standards in the conduct of our business and to operating in an honest and transparent way, without bribery or corruption being used to obtain any unfair advantage.

We have established an internal policy “The Anti-Bribery & Corruption Policy”, supported by training and adequate procedures and controls which apply strictly to all our employees, directors, agents, consultants, contractors and to any other person or bodies acting on behalf of the Group or with whom we do business within all countries, areas and functions in which we operate.

This, our Public Statement, is made in order to communicate to potential business partners, clients, or future employees what they can expect with regard to Linxia’s approach to Bribery and Corruption in any external engagement or relationship. 

Our Zero Tolerance stance

Linxia will not condone any employee, contractor, client or any party with which it does business or who might conduct business on its behalf:

  • promising or making or offering a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  • accepting, requesting or agreeing to receive a payment, gift or hospitality in the expectation or belief that a business advantage will be granted, or as a reward for a business advantage already given;
  • giving gratification or bribing a public official in employment or service anywhere in the world in the course of conducting business for or with Linxia;
  • taking any action aimed at securing a commercial, contractual or regulatory advantage for Linxia that is unethical or results in personal monetary advantage for a Linxia employee, related individual, client or related client entity or person;
  • making a facilitation payment to any individual in the course of conducting business for or with Linxia;
  • making a charitable contribution knowing that there is a political interest in that charity, or where such a contribution would not be considered legal and ethical under local laws and practices.

Linxia will not knowingly conduct business or continue a business relationship where an employee, service provider, agent, reseller or contractor acts outside of our anti-bribery and corruption principles.

Trade Compliance

In its capacity of reseller of Dell, Linxia will not contract with or otherwise do business with any individual, company, organization or other entity, or with, in or involving any country or territory (including North Korea, Cuba, Iran, Sudan, Syria, and Crimea), that is the subject or target of any U.S. or other national government financial and economic sanctions or trade embargoes or otherwise identified on a list of prohibited, sanctioned, debarred, or denied parties, including those imposed, administered or enforced from time to time by the U.S. government through the Office of Foreign Assets Control ("OFAC") of the U.S. Department of Treasury, the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, or the U.S. Department of State, the United Nationals Security Council, the European Union, or Her Majesty’s Treasury of the United Kingdom (collectively, “Sanctions”), without having first obtained any required license or other government authorization or in any manner which would result in a violation of Sanctions.

It is important for Linxia to ensure that, its products, software and services will not be exported, re-exported, sold, leased or otherwise transferred to, or utilized by, an end-user engaged in any of the following activities: (i) activities related to weapons of mass destruction, including any activities related to the design, development, production or use of: (A) nuclear weapons, materials or facilities; (B) missiles or the support of missile projects; or (C) chemical or biological weapons; (ii) terrorist activities (iii) military end uses in or connected with certain government owned or controlled corporations of such countries as identified by U.S. and other applicable government licensing authorities; (iv) exploration or production of oil and gas in Arctic, deepwater (greater than 500 feet), or shale formations in Russia or in, by, or with Russian companies, territories, or any other entities as identified by BIS and/or OFAC.

Reporting violations

If you observe conduct that may contravene any anti-bribery and corruption and Sanctions legislations, please contact the Harel Mallac Group Legal Counsel.  Suspected violations will be reviewed and investigated as appropriate and may lead to disciplinary action.  Any such reporting will be treated as confidential to the extent permitted by law.  The Harel Mallac Group strictly prohibits retaliation for good faith reports of suspected misconduct.  

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