Anti-Bribery, Anti-Corruption, and Anti-Money Laundering (ABC-AML) Policy
Effective Date: January 10, 2019
Last Reviewed: November 1, 2024
Purpose
DRILLIT Energy and Mining (“DRILLIT”) is committed to conducting business ethically and transparently, in full compliance with all applicable anti-bribery, anti-corruption, and anti-money laundering laws. This policy establishes the framework for preventing, detecting, and addressing bribery, corruption, and money laundering within DRILLIT’s operations, supply chains, and partnerships.
Scope
This policy applies to all DRILLIT employees, directors, officers, contractors, suppliers, agents, and business partners globally.
Policy Statements
1. Zero Tolerance for Bribery and Corruption
Definition of Bribery: Offering, giving, receiving, or soliciting anything of value (e.g., gifts, payments, favors) to influence a person’s actions or decisions improperly.
DRILLIT strictly prohibits all forms of bribery and corruption in any business dealings, regardless of local customs or practices.
Employees and third parties acting on DRILLIT’s behalf must not offer or accept bribes, kickbacks, or illicit payments under any circumstances.
2. Compliance with Anti-Bribery and Anti-Corruption Laws
DRILLIT complies with all applicable laws and regulations, including but not limited to:
U.S. Foreign Corrupt Practices Act (FCPA)
UK Bribery Act
Canadian Corruption of Foreign Public Officials Act (CFPOA)
Relevant local laws in jurisdictions where we operate.
3. Prohibition of Facilitation Payments
Facilitation payments—small payments made to expedite routine government actions—are strictly prohibited unless a legitimate safety concern arises. In such cases, the payment must be documented and reported.
4. Anti-Money Laundering (AML) Compliance
Definition of Money Laundering: Concealing the origins of funds obtained through illegal activities to make them appear legitimate.
DRILLIT implements measures to prevent its operations from being used to launder money or finance terrorism. This includes conducting due diligence on clients, suppliers, and business partners to ensure they comply with legal and ethical standards.
5. Gifts, Hospitality, and Entertainment
Modest and reasonable gifts, hospitality, or entertainment may be accepted or offered, provided they:
Are not intended to influence decisions or actions.
Comply with local laws and company policies.
Are fully disclosed to management.
Lavish or excessive gifts and entertainment are strictly prohibited.
6. Accurate Books and Records
DRILLIT ensures all financial transactions are accurately recorded in accordance with applicable accounting standards. Falsifying records to conceal bribery, corruption, or money laundering is strictly prohibited.
7. Third-Party Relationships
DRILLIT requires all agents, consultants, suppliers, and other third parties to adhere to this policy when acting on our behalf. Third parties must undergo due diligence to identify and mitigate risks of bribery, corruption, or money laundering.
8. Whistleblowing and Reporting
Employees and stakeholders are encouraged to report any suspected or actual bribery, corruption, or money laundering activities through DRILLIT’s confidential reporting channels. DRILLIT ensures protection against retaliation for whistleblowers.
Implementation and Enforcement
1. Training and Awareness
All employees and relevant third parties must complete regular training on anti-bribery, anti-corruption, and anti-money laundering practices.
2. Risk Assessment
DRILLIT conducts periodic risk assessments to identify and address potential vulnerabilities in operations and supply chains.
3. Monitoring and Auditing
Regular audits and monitoring are conducted to ensure compliance with this policy. Non-compliance will be addressed with corrective actions, including potential disciplinary or legal measures.
4. Consequences of Policy Violations
Violations of this policy may result in disciplinary action, including termination of employment or contracts. Severe violations may also lead to prosecution under applicable laws.
Governance and Review
This policy is overseen by the DRILLIT leadership team and reviewed annually or as needed to reflect changes in laws, regulations, or business practices.
Reporting Concerns
Concerns or suspected violations can be reported via:
Email: info@drilitenergy.com
Phone: +1 (780)863-0160
Approved by: Francis Amankwa, CEO
Date: January 10, 2019
Last Reviewed: November 1, 2024
Purpose
DRILLIT Energy and Mining (“DRILLIT”) is committed to conducting business ethically and transparently, in full compliance with all applicable anti-bribery, anti-corruption, and anti-money laundering laws. This policy establishes the framework for preventing, detecting, and addressing bribery, corruption, and money laundering within DRILLIT’s operations, supply chains, and partnerships.
Scope
This policy applies to all DRILLIT employees, directors, officers, contractors, suppliers, agents, and business partners globally.
Policy Statements
1. Zero Tolerance for Bribery and Corruption
Definition of Bribery: Offering, giving, receiving, or soliciting anything of value (e.g., gifts, payments, favors) to influence a person’s actions or decisions improperly.
DRILLIT strictly prohibits all forms of bribery and corruption in any business dealings, regardless of local customs or practices.
Employees and third parties acting on DRILLIT’s behalf must not offer or accept bribes, kickbacks, or illicit payments under any circumstances.
2. Compliance with Anti-Bribery and Anti-Corruption Laws
DRILLIT complies with all applicable laws and regulations, including but not limited to:
U.S. Foreign Corrupt Practices Act (FCPA)
UK Bribery Act
Canadian Corruption of Foreign Public Officials Act (CFPOA)
Relevant local laws in jurisdictions where we operate.
3. Prohibition of Facilitation Payments
Facilitation payments—small payments made to expedite routine government actions—are strictly prohibited unless a legitimate safety concern arises. In such cases, the payment must be documented and reported.
4. Anti-Money Laundering (AML) Compliance
Definition of Money Laundering: Concealing the origins of funds obtained through illegal activities to make them appear legitimate.
DRILLIT implements measures to prevent its operations from being used to launder money or finance terrorism. This includes conducting due diligence on clients, suppliers, and business partners to ensure they comply with legal and ethical standards.
5. Gifts, Hospitality, and Entertainment
Modest and reasonable gifts, hospitality, or entertainment may be accepted or offered, provided they:
Are not intended to influence decisions or actions.
Comply with local laws and company policies.
Are fully disclosed to management.
Lavish or excessive gifts and entertainment are strictly prohibited.
6. Accurate Books and Records
DRILLIT ensures all financial transactions are accurately recorded in accordance with applicable accounting standards. Falsifying records to conceal bribery, corruption, or money laundering is strictly prohibited.
7. Third-Party Relationships
DRILLIT requires all agents, consultants, suppliers, and other third parties to adhere to this policy when acting on our behalf. Third parties must undergo due diligence to identify and mitigate risks of bribery, corruption, or money laundering.
8. Whistleblowing and Reporting
Employees and stakeholders are encouraged to report any suspected or actual bribery, corruption, or money laundering activities through DRILLIT’s confidential reporting channels. DRILLIT ensures protection against retaliation for whistleblowers.
Implementation and Enforcement
1. Training and Awareness
All employees and relevant third parties must complete regular training on anti-bribery, anti-corruption, and anti-money laundering practices.
2. Risk Assessment
DRILLIT conducts periodic risk assessments to identify and address potential vulnerabilities in operations and supply chains.
3. Monitoring and Auditing
Regular audits and monitoring are conducted to ensure compliance with this policy. Non-compliance will be addressed with corrective actions, including potential disciplinary or legal measures.
4. Consequences of Policy Violations
Violations of this policy may result in disciplinary action, including termination of employment or contracts. Severe violations may also lead to prosecution under applicable laws.
Governance and Review
This policy is overseen by the DRILLIT leadership team and reviewed annually or as needed to reflect changes in laws, regulations, or business practices.
Reporting Concerns
Concerns or suspected violations can be reported via:
Email: info@drilitenergy.com
Phone: +1 (780)863-0160
Approved by: Francis Amankwa, CEO
Date: January 10, 2019