Anti-Bribery
& Corruption
Policy
At Engines For Sale USA, we operate with uncompromising integrity. This policy outlines our zero-tolerance commitment to ethical business conduct across every transaction, relationship, and market we serve.
Built on Integrity
Engines For Sale USA is committed to conducting all business with the highest standards of ethics and integrity. We strictly prohibit any form of bribery, corruption, or improper influence — whether in public or private dealings.
Zero Tolerance
We maintain an absolute prohibition on all forms of bribery and corrupt practices. No business outcome justifies compromising our ethical standards.
Transparency First
All business transactions are recorded accurately and completely. Our financial records reflect the true nature of every deal we undertake.
Team Accountability
Every employee, partner, and supplier operating under our banner is expected to uphold these principles without exception.
Ethical Gifts Policy
We apply strict controls over gifts, entertainment, and hospitality to ensure no improper influence is ever created or perceived.
Legal Compliance
We operate in full compliance with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all applicable anti-corruption laws.
Continuous Improvement
This policy is reviewed annually and updated to reflect evolving legal standards and best practices in corporate ethics.
Why Integrity Matters
What This Policy Covers
Our anti-bribery and corruption framework covers all areas of our business operations, protecting our customers, employees, and the communities we serve.
Direct Bribery
No employee may offer, promise, give, request, or accept any bribe — monetary or otherwise — to influence any business decision.
Facilitation Payments
We prohibit all facilitation payments, including unofficial payments to government officials to expedite routine administrative actions.
Gifts & Entertainment
Gifts and entertainment must be modest, reasonable, and never given with the intent to gain improper business advantage.
Political Contributions
No company funds may be used for political contributions or to gain favor with public officials on behalf of Engines For Sale USA.
Charitable Donations
All charitable and sponsorship activities are transparent, properly documented, and never used as a vehicle for bribery.
Record Keeping
Accurate, complete records of all transactions are maintained. Falsification of records to conceal corrupt payments is strictly forbidden.
Conflicts of Interest
Employees must disclose any personal interest that may conflict with the interests of the company or its customers.
International Operations
Our anti-corruption standards apply globally. All cross-border transactions comply with FCPA and applicable international law.
Prohibited Conduct
The following actions are strictly forbidden under our anti-bribery policy and may result in immediate disciplinary action, up to and including termination and criminal referral.
Offering, promising, or paying anything of value to influence a government official or private party's decisions
Accepting gifts, cash, or benefits that could influence your professional judgment or create an obligation
Making or approving payments through third parties knowing the funds will be used as bribes
Creating false invoices or disguising corrupt payments as legitimate business expenses
Retaliating against employees who report suspected bribery or corruption in good faith
Pressuring employees, suppliers, or customers to participate in any form of corrupt practice
Speak Up.
We're Listening.
If you observe, suspect, or are pressured into any corrupt activity, report it immediately. Every report is taken seriously and investigated thoroughly.
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1Contact Your Manager Raise concerns directly with your direct supervisor or department head if you feel comfortable doing so.
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2Call Us Directly Reach our compliance team at +1 (323) 696-7549 for confidential guidance.
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3Submit in Writing Send written concerns to our compliance office at 1910 George Dieter Dr, El Paso, TX 79936.
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4Anonymous Reporting You may report anonymously. We guarantee no retaliation for good-faith reports made under this policy.
Consequences of Non-Compliance
Violations of this policy carry serious consequences for individuals and the company. We do not compromise on enforcement.
Criminal Prosecution
Bribery and corruption are criminal offenses that can result in imprisonment and substantial personal fines under federal and state law.
Termination
Employees found to have engaged in or facilitated corrupt conduct will face immediate termination without exception.
Civil Liability
The company and individuals involved may face significant civil penalties, lawsuits, and compensation claims.
Regulatory Action
Regulatory bodies may impose fines, trading restrictions, and licensing consequences on the company.
Reputational Damage
Corruption scandals permanently damage customer trust and brand reputation — assets we have worked hard to build.
Supplier Blacklisting
Third-party partners found in violation of our standards will be immediately removed from our approved supplier list.
Training &
Awareness
Anti-corruption is not just policy — it's a culture. Every person in our organization receives training and guidance to ensure they understand and live these standards.
Onboarding Training
All new employees complete mandatory anti-bribery and ethics training before beginning work at Engines For Sale USA.
Annual Refresher
Existing employees complete updated compliance training every year, reflecting current regulations and real-world scenarios.
Role-Specific Modules
Sales, procurement, and finance teams receive specialized training tailored to the corruption risks specific to their roles.
Leadership Accountability
Senior management leads by example and completes enhanced training covering governance, oversight, and tone-at-the-top expectations.
Third-Party Screening
We apply rigorous due diligence to all business partners, agents, and suppliers to ensure our integrity standards extend across our supply chain.
Background Checks
All new suppliers and agents undergo thorough background screening before engagement, including sanctions and PEP checks.
Contractual Obligations
Our contracts include specific anti-bribery clauses, requiring partners to comply with equivalent ethical standards.
Ongoing Monitoring
Existing relationships are periodically reviewed. Red flags trigger immediate reassessment and potential termination.
Risk Assessment
Higher-risk jurisdictions and sectors receive enhanced scrutiny before we authorize any business activity.
Whistleblower Protection
No employee will ever face retaliation for reporting suspected bribery or corruption in good faith. This is a fundamental commitment we take seriously.
Questions About
This Policy?
If you have questions about our anti-bribery and corruption policy, need to report a concern, or wish to learn more about how we do business, our compliance team is here to help.