STEMGuyana Inc. Code Of Conduct

STEMGuyana Inc. Code Of Conduct

INTRODUCTION
STEMGuyana Inc. is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act (UKBA) and similar laws in other countries that prohibit improper payments to obtain a business advantage. This document describes STEMGuyana Inc. ’s Policy prohibiting bribery and other improper payments in the conduct of STEMGuyana Inc. business operations and employee responsibilities for ensuring implementation of the Policy.  Questions about the Policy or its applicability to particular circumstances should be directed to Karen Abrams who serves as the Compliance Officer.

POLICY OVERVIEW
STEMGuyana Inc. strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in   the world, whether involving government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and STEMGuyana Inc. to possible criminal prosecution, reputational harm or other serious consequences.

This Policy applies to everyone at STEMGuyana Inc., including all officers, employees and agents or other intermediaries acting on STEMGuyana Inc. are behalf. Each officer and employee of STEMGuyana Inc. has a personal responsibility and obligation to conduct STEMGuyana Inc. ’s business activities ethically and in compliance with all applicable laws based on the countries wherein STEMGuyana Inc. does business. Failure to do so may result in disciplinary action, up to and including dismissal.

Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of STEMGuyana Inc. ’s business.

STEMGuyana Inc. has developed a comprehensive program for implementing this Policy, through appropriate guidance, training, investigation and oversight. Karen Abrams has overall responsibility for the program, supported by the executive leadership of STEMGuyana Inc. .

Karen Abrams is responsible for giving advice on the interpretation and application of this policy, supporting training and education, and responding to reported concerns. The prohibition on bribery and other improper payments applies to all business activities, but is particularly important when dealing with government officials.

POLITICAL DONATIONS
STEMGUYANA explicitly prohibits the making of political contributions to any political party in Guyana.

DISCRIMINATION
Neither STEMGuyana Inc. or any of its partner STEM clubs, employees, or members discriminate on the basis of ethnicity, race, gender, sexual orientation, religion, disability or any possible difference in society.