Anti - corruption Policy
1. Overview and Background
This document summarizes Nahla Consulting & Strategy ltd. ("Nahla”) zero tolerance policy of bribery and corruption.
Among other clients Nahla provides services to international clients, Nahla is committed that all its activities comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), the United Kingdom Bribery Act 2010 ("Bribery Act"), the Israeli Penal Code (2008) ("the Penal Code") and any relevant analogue anti-bribery legislation (all together: “Anti-Bribery Laws”).
This document provides guidelines for compliance with the Anti-Bribery Laws and is applicable to Nahla, its officers, directors, and employees.
As detailed in this document, the use of the funds or assets of Nahla for any illegal, improper, or unethical purpose is prohibited. Improper gift giving or offering anything of value to any individual to wrongfully influence an act or decision is absolutely prohibited, could jeopardize Nahla’s operations and reputation, and will not be tolerated by Nahla.
2. Guidelines
Nahla, its officers, directors and employees shall not offer, pay, give, receive, promise to pay or give, authorize the payment or giving of any money or anything of value, directly or indirectly, to any government official or employee (including official or employee of governmental companies, municipalities and public international organizations), any political candidate, any holder of public office or candidate for public office (all together "Public Officials"), with the intention of influencing him or her in his or her capacity as a Public Official to obtain or retain business or to direct business to any person or to secure an improper advantage or to induce or reward improper conduct.
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In addition, Nahla and its officers, directors and employees shall not make any such offering or payment to any person knowing or having reason to believe that all or part of it could be used for a purpose described above and shall refuse any offering from any Public Official or other third party to pay or give them any payment.
3. Gifts
The guidelines are that Nahla, its officers, directors and employees do not to give gifts, or cover travel and business entertainment expenses of any kind in connection with any services given by Nahla or received by Nahla, directly or indirectly, even if permitted by law and regulations; or transfer anything of value, offer, promise to give a financial or other advantage or request, agree to receive or accept a financial or other advantage; or to secure an improper benefit on behalf of Nahla or to improperly influence any entity or person.
4. No Political Contributions
Contributions to political parties or organizations and to Public Officials are not allowed.
5. Anti-Bribery Red Flags
Nahla personnel should be on the lookout for “red flags” that might indicate a potential issue relating to the Anti-Bribery Laws. These “red flags” are critical since the Anti-Corruption Laws impose liability not only on the basis of actual knowledge of a potential bribe, but also on the basis that a representative of Nahla “should have known” about a potential bribe.
6. Accurate Books and Records
Nahla is committed to maintaining accurate books and records that accurately and fairly reflect Nahla’s business transactions. Consistent with this commitment, Nahla, its officers, directors, and employees shall not mischaracterize or otherwise conceal in Nahla’s books and records any payments that they know or have reason to know are in violation of the Anti-Bribery Laws.
7. Training
Nahla is committed to conducting periodic training for all its employees in the area of Ethics, Anti Bribery and Anti-Corruption compliance, and they are required to certify their understanding of this Nahla and to comply with it.