It has implemented and will enforce effective systems to counter bribery and comply with all applicable local and international laws on this subject
Specifically, Stellar Group complies with the following two pieces of legislation:
The Bribery Act 2010 (UK) that came into force in July 2011. Whilst the Bribery Act is a piece of UK legislation it applies to Stellar Group’s significant activities not only in the UK but also in every country where it operates. Clearly, Hull Blyth also complies and upholds all laws relevant to countering bribery and corruption in all the jurisdictions in which it operates.
The Foreign Corrupt Practice Act (FCPA) of 15 U.S.C. §§ 78dd-1.
The FCPA applies to any person who has a certain degree of connection to the United States and engages in foreign corrupt practices. The Act also applies to any act by U.S. businesses, foreign corporations trading securities in the United States, American nationals, citizens, and residents acting in furtherance of a foreign corrupt practice whether or not they are physically present in the United States. This is considered the nationality principle of the act.
This act was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. In the case of foreign natural and legal persons, the Act covers their actions if they are in the United States at the time of the corrupt conduct. This is considered the protective principle of the act.
Further, the Act governs not only payments to foreign officials, candidates, and parties, but any other recipient if part of the bribe is ultimately attributable to a foreign official, candidate, or party. These payments are not restricted to just monetary forms and may include anything of value. This is considered the territoriality principle of the act.
Stellar Group's TRACE certification highlights our commitment to transparent business practices and makes us a better business partner for multinational corporations. TRACE certifications entails online anti-bribery training and enrolls Stellar Ghana on the list of intermediaries who have met the TRACE standard of review for transparency in international commercial transactions.
As part of its certification, Stellar Group is required to complete a mandatory anti-bribery training course, adopt an anti-bribery code of conduct, and update their due diligence information annually.
TRACE International, and American organization, was founded in 2001 by in-house anti-bribery compliance experts to achieve economies of scale and set a common standard for two shared elements of anti-bribery compliance programs: due diligence reviews of commercial intermediaries and anti-bribery training for the global supply chain.
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