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Ethics and Business Conduct


“Winning Business the Right Way”

All Omni personnel, including any employee, contractor, representative, advisor consultant or any other person performing services for or on Omni’s behalf or with Omni is responsible for knowing Omni’s Anti-Bribery & Gift Policy and closely adhering to the requirements of the policy. The failure of any Omni personnel to follow this policy will result in disciplinary action, up to and including suspension or termination of employment. The failure of any vendor doing business with Omni to adhere to this policy will result in the termination of contracts or orders with that vendor.

Omni personnel are expected to report any actual or suspected violations of the Anti-Bribery & Gift Policy – whether involving a colleague, a manager or supervisor, or anyone else doing business for, with or on behalf of Omni. Reports may be made to the head of your department, the Head of HR and Corporate Services or the General Counsel. No employee will ever be punished or reprimanded for reporting actual or suspected violations of Omni’s Anti-Bribery & Gift Policy. No vendor will be disadvantaged for reporting actual or suspected violations of Omni’s Anti-Bribery & Gift Policy.

Bribery & Kickbacks

Omni is committed to “winning business the right way.” As part of this commitment Omni does not and will not tolerate bribery of, or kickbacks to or from, any private person or government official. Even if Omni loses business or encounters delays, we will never bribe, accept bribes, provide or accept kickbacks to or from any private person or government official directly or indirectly (through a third party).

Anti-bribery and anti-corruption laws are complex and the consequences for violating these laws are severe and disruptive to the entire Company. For this reason all Omni personnel must avoid any activity that could be construed as bribery.

This means Omni personnel may never offer, attempt to offer, authorize or promise any sort of bribe or kickback for the purpose of obtaining or retaining business or for an improper advantage. Nor must they accept any sort of bribe or kickback from a vendor or other party external to Omni that may have an interest in doing business with Omni.

A “bribe” is an offer or gift of anything of value or any advantage intended to improperly influence the actions of the recipient or other person(s). Bribes may include money, gifts, travel or other expenses, hospitality, discounts, favours, business or employment opportunities, political or charitable contributions, or any benefit or consideration, direct or indirect.

A “kickback” is the return of a sum already paid or due to be paid as a reward for awarding or fostering business.

A “government official” is any national, state, regional or local government official or employee, a political candidate, a representative of an organization such as the World Bank, or an official or employee of government-owned or government-controlled entities, such as state-owned oil companies.

Omni complies with all international laws, treaties and regulations that forbid bribery, including local laws where we conduct business, the U.S. Foreign Corrupt Practices Act and the Singapore Prevention of Corruption Act.

To “win business the right way” Omni personnel must follow these laws wherever we do business regardless of local custom.


Our policy for receiving gifts from outside is as much of a reflection of Omni’s commitment to “winning business the right way” as our Anti-Bribery policy. Omni prohibits the offer or receipt of gifts or entertainment that are of a value not consistent with the standards of our industry and profession or that appear to be intended to unfairly influence the outcome of any business transactions. Employees may only accept gifts and offers of entertainment that are:

  • Modest in value;
  • Infrequent;
  • Unsolicited; and
  • Would not embarrass the employee or the Company if the gift was publically disclosed

Employees may not accept cash or cash equivalents (stocks, equities, share options, etc.) under any circumstance.

Employees are required to report all gifts received from outside parties to the company through the online Gift Reporting portal. Employees must report gifts within seven (7) days of receipt. Employees are expected to decline or return gifts that deviate from the policy. If it is not possible to return a gift, other than cash, for commercial reasons or if return of the gift could harm a legitimate business relationship then the employee is required to immediately handover the gift to the designated contact in the office or workplace. The company will donate the gift to charity, share it with all on-site employees or include the gift in a pre-scheduled lucky-draw.

Omni personnel may accept unsolicited offers to dine with clients, prospective clients, suppliers, contractors, consultants, and the providers of other services provided that the cost of the meal meets all four criteria above. Gifts received by Omni personnel at such meals must be reported as outlined above.

For a complete outline of Omni’s policy, please refer to our policy manuals.