Terms & Conditions

BE THE PRO

PROHIBITION OF BRIBERY AND CORRUPTION

At Complex, we value integrity and ethical behavior in the conduct of our business.

Complex is committed to compliance with anti-corruption and anti-bribery laws in the UK.

We do business and to implement policies and procedures that prohibit bribery and corruption by our associates and anyone representing our interests.

The purpose of this policy is to define Complex our position and responsibilities and requirements for the deployment of controls regarding the prevention of bribery and corruption.

 

Scope

This policy applies to all complex employees, associates, independent contractors, consultants, agents and vendors.

Definition

For the purposes of this policy, bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favor, or a financial or other advantage from another to influence a business outcome improperly, or to induce or reward improper conduct. Bribery and corruption – whether involving government officials or commercial entities, including joint ventures – can be direct or indirect through third parties such as agents, brokers and joint venture partners. Under the U.K. Bribery Act, facilitation payments now constitute bribery even though in some countries, including the U.S., certain facilitation payments are legal.

Policy

Prohibition of Bribery and Corruption

COMPLEX DOES NOT TOLERATE ANY FORM OF BRIBERY OR CORRUPTION.

Under no circumstance shall any Complex person or anyone acting on Complex’s behalf give, pay, offer, promise to pay, or authorize the giving or payment of money or any other thing of value to any foreign government official or client, vendor or other business partner for any improper purpose or in violation of applicable law, including the local laws of any relevant country.

Nor shall any Complex Person or anyone acting on Complex  behalf give, pay, offer, promise to pay, or authorize the giving or payment of money or any other thing of value to any person, knowing or being aware of a substantial probability that the payment or promise to pay will be improperly passed on to a foreign government official or Complex client, vendor or other business partner.

A foreign government official includes any officer, employee, or person acting in an official capacity for or on behalf of any foreign, domestic, federal, territorial, state or local governmental authority or any department, agency, or instrumentality thereof (including state-owned entities) and any public organization.

 

COMPLEX  POLICY STRICTLY PROHIBITS “FACILITATION PAYMENTS,”

Resolving any Uncertainty Regarding this Policy

No Complex person should attempt to resolve questions regarding the interpretation or applicability of this policy on their own. Rather, all questions of interpretation or applicability must be referred to:

Mr Juan Venegas Advisor Mr Juan Carlos Venegas

CIPFA (Affil), AAIA, ACPA, ICFS, FCFIP, FICPA, CFC

Forensic Accountant & Counter Fraud Specialist

Adequate Procedures; Due Diligence

Complex shall regularly and systematically identify bribery and corruption risks in its business and implement adequate risk-based procedures aimed at preventing bribery and corruption. Such procedures shall require adequate due diligence and the taking of reasonable precautions to ensure that business relationships are formed with reputable and qualified partners, agents, and representatives.

Procurement

Complex shall address bribery and corruption risk in procurement and supply chain activities including by ensuring that payments made for goods and services are reasonable and appropriately documented.

Accounting; Books and records

Complex shall maintain adequate accounting books and records which properly, completely and fairly document including all financial transactions and asset and funds dispositions wherever they take place.  In addition, Complex will maintain a system of internal accounting controls sufficient to provide reasonable assurances that, among other things, transactions have been executed in accordance with management’s specific authorization and recorded in accordance with generally accepted accounting principles. Complex shall further maintain written evidence to document compliance with this policy.

Compulsory Compliance and Reporting

It is the obligation of every Complex Person to comply with this policy.  No Complex Person has the authority to act contrary to the provisions of this policy or to authorize, direct, or condone violations of it by any other Complex Person or by any agent or any other person.

MR JUAN VENEGAS OR HIS OR HER DESIGNEE SHALL CONDUCT ADHOC INTERNAL REVIEWS.

Sanction for Breach

Complex Will refer the Matter without hesitation the Police and Companies legal representatives.

 

Communication and Education

Complex shall communicate this policy and relevant guidance to all Complex associates, through established internal communication channels. Responsibilities

All managers and associates share responsibility for the detection of bribery and corruption activities and for the deployment and compliance with anti-bribery and corruption policies, initiatives and procedures.

All Complex associates are responsible for compliance with the law and the policy and subject to possible disciplinary action (including termination) for violation of this policy and possible legal proceedings for violation of law.

Complex management is responsible for;

Implementing policies and procedures meant to identify bribery and corruption activities.

Educating associates and promoting awareness of bribery and corruption policies and procedures and the ethical principles subscribed to by Complex Ensuring all bribery and corruption issues, suspected or actual, are reported immediately through Complex at [email protected]  or notifying :

Mr Juan Carlos Venegas

CIPFA (Affil), AAIA, ACPA, ICFS, FCFIP, FICPA, CFC

Forensic Accountant & Counter Fraud Specialist

Kemp House

160 City Road

LONDON

EC1V 2NX

Contact Details

020 7566 4056

02890 201998

07703 626750

[email protected]

[email protected]

www.faforensics.co.uk

 

 

Payment & Security

Customers placing orders via the website can pay for items as they are ordered by credit card, debit card or PayPal.

We will do all that we reasonably can to ensure that all of the information you give us when paying for the goods is secure by using an encrypted secure payment mechanism. However, in the absence of negligence on our part we will not be legally responsible to you for any loss that you may suffer if a third party gains unauthorised access to any information that you give us.

Your credit card or debit card will only be charged when the goods are dispatched.

All payments by credit card or debit card need to be authorised by the relevant card issuer. We may also need to use extra security steps.

If your payment is not received by us and you have already received the goods, you:

  • Must pay for such goods within 30 days, or
  • Must return them to us as soon as possible. If so, you must keep the goods in your possession, take reasonable care of them (including ensuring that you follow any instructions or manuals given with the goods) and not use them before you return them to us

If you do not return any goods (such as where you have not paid for them) we may collect the goods from you at your expense. We will try to contact you to let you know if we intend to do this.

Nothing in this clause affects your legal rights to cancel the contract during the ‘cooling off’ period referred to in these terms and conditions.

The price of the goods:

  • Is in pounds sterling (£)(GBP)
  • Includes VAT at the applicable rate
  • Does not include the cost of delivering the goods (see below for further details about delivery)
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