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Compliance Ethics and Commitment

"We know Business"




Our commitment to ethics and compliance checks is communicated widely and regularly in many sectors — and is an essential aspect and core value of how we conduct our business.

First Edge has a zero-tolerance policy for compliance violations and reinforces full integrity in every business action from every candidate.

Since 2012, we have implemented a comprehensive Compliance Management System to promote our services towards unethical behaviour directed at curtain clients that needs to be vetted. We have been consistent with the highest standards of our principle associates. This system aims to prevent and detect violations of law, regulation and company policy, and to cultivate an ethical business culture globally.

Key elements of our Compliance Management Service include:

·         A comprehensive compliance governance structure

·         The First Edge Code of Conduct

·         Policies, procedures and controls

·         Monitoring and auditing practices

·         An annual compliance risk assessment (with related mitigation plans and

·         processes for continuous improvement)

·         Ethics and compliance communications focusing on maintaining logistics

·         Keeping clients Updated on any new banking resolution process

We also continued to focus on:
Embedding a culture of integrity by reinforcing our strong tone of top institutions
Reinforcing ownership of business integrity by senior leaders, as well as overall business accountability for program implementation and results
Increasing regional leadership and oversight of ethics and compliance across the business
Zero-tolerance policy

We continued to implement our zero-tolerance policy last year, requiring 100% integrity in all business practices. Management expects all employees to comply with applicable legal and company requirements. Any identified violations are addressed swiftly, consistently and fairly. We also furthered our phase-out of sales agents and consultants — a mandated process initiated in 2008. Alcatel-Lucent has not engaged a new sales agent or consultant since 2009.

The status of the zero-tolerance policy is reviewed regularly at the highest levels of the company, including review by the Ethics & Compliance Council and the Board of Directors.

We engage in only lawful means of obtaining information with clients approval. We comply with all international trade laws, including applicable export, import and sanction laws and regulations in the countries where we conduct business.

Our anti-trust law policy and guidelines for most companies are readily available through most company regulations. When in doubt, they are urged to consult the Law Division to ensure their activities comply with competition/anti-trust laws.

Suppliers and contractors from whom we consult on goods and services are also required to comply with our compliance ruling. To enforce this obligation, we have the right to conduct an audit confirming compliance. Any knowledge or reasonable suspicion that an anti-trust violation has occurred will be reported to relevant authorities. In case of a violation of such laws, we may terminate our service immediately in case of any further violation.


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