Anti-Corruption and Bribery Policy

Policy Brief and Purpose

Resolve Collaboration Services Corp. (Resolve) values honesty, integrity, transparency, and professionalism in dealings with clients, suppliers, competitors, and government officials alike. It is the policy of Resolve to compete fairly and engage in business practices that comply with the Corruption of Foreign Public Officials Act (“CFPOA”) and the Criminal Code (“Criminal Code”) in Canada together with all other anti-corruption and anti-bribery laws and regulations applicable to the Resolve’s business anywhere in the world.
This Policy applies to all directors, officers, employees, and independent contractors of Resolve worldwide. Its purpose is to advise Resolve Personnel of their anti-bribery and anti-corruption obligations and to ensure compliance by Resolve Personnel with Anti-Corruption Laws. It also provides guidance on identifying potential risks, dealing with challenging situations, and reporting when those situations violate or may lead to a violation of this Policy and Anti-Corruption Laws.
In addition, Resolve expects its agents, consultants, representatives, lobbyists, suppliers, vendors, contractors, advisors, business partners and any other person that performs services for or on behalf of the Resolve to comply with the principles contained in this Policy.
Resolve has zero tolerance for corrupt activities of any kind. Bribes or other improper or unauthorized payments, or acts that create the appearance of promising, offering, giving, or authorizing such payments, are prohibited by this Policy. Resolve Personnel are expected to adhere to both the spirit and the letter of this Policy with respect to the Resolve’s business anywhere in the world.
Failure to comply with this Policy or Anti-Corruption Laws will be grounds for disciplinary action up to and including termination of employment or other relationship with Resolve, may require restitution and may lead to civil or criminal action against individual Resolve Personnel. If Resolve Personnel are in or aware of a situation that they believe may violate or lead to a violation of this Policy, they must ask for guidance from their manager or other personnel in a superior position or follow the guidelines described in the Resolve Code of Business Conduct.

Prohibition on Corruption

Resolve Personnel are prohibited from engaging in corrupt practices, including bribes, in the Resolve’s business dealings both in the private and government sectors and such conduct will often constitute a violation of one or more Anti-Corruption Laws.
Resolve Personnel are prohibited from engaging in corrupt practices, including bribes, in the Resolve’s business dealings both in the private and government sectors and such conduct aResolve Personnel must not directly or indirectly make, offer or promise to make, or authorize any bribes, kickbacks or other improper payments, benefits or advantages to any person, individual, entity or organization, including, but not limited to, any Public Official or any employee, official, representative or agency of any:will often constitute a violation of one or more Anti-Corruption Laws.
For any improper purpose, including for the purpose of influencing, inducing or rewarding any act, omission or decision to secure an improper advantage or to obtain or retain business.
This Policy also prohibits “quid pro quo” payments, meaning that the payment is made with the expectation of receiving in return an improper benefit or advantage.
Resolve Personnel are also prohibited from soliciting or accepting any bribe, kickback or other improper payments or benefits from the Resolve’s vendors or other persons in relation to the Resolve’s business.

Travel, Gifts and Meals & Entertainment

Resolve hosted meals and entertainment expenses must not exceed $200 per guest and hosted travel expenses must not exceed $350 per guest. Any expenses exceeding these amounts require prior supervisor approval, must have a valid business purpose, be reasonable by local standards, be properly recorded in Resolve’s books and include supporting justification documents.
Gifts should be promotional marketing items or traditional ceremonial gifts with a value of less than $200. Gifts of a value exceeding $200 require prior supervisor approval.
Resolve Personnel will not provide or accept gifts, services, or entertainment from individuals or companies seeking to do or currently doing business with Resolve unless the gift, service or entertainment meets all of the following criteria:
Resolve Personnel who believe gifts, service or entertainment may fall outside these criteria should disclose such items through the CEO and seek advice accordingly. Unless an exception is approved in writing, such gift, service or entertainment should be declined.
Political Contributions

Political Contributions

Resolve does not contribute to political parties or organizations, or to any individual who holds or is a candidate for public office. Personnel acting on behalf or in the name of Resolve must never endorse or appear to endorse political parties or organizations, or individuals who hold or are candidates for public office, engage in lobbying activities, or make political contributions.

Accounting and record

Accounting and record keeping

In addition to the Resolve’s other obligations with respect to its financial statements and reporting, AniCorruption Laws require complete, thorough and accurate record keeping. Resolve Personnel must record each transaction or payment in the books and records of the company so that Resolve can fulfil these requirements. Any false or misleading statements or entries in the Resolve’s books and records are violations of not only Anti-Corruption Laws and Resolve’s Code of Business Conduct but are also acts of fraud and will not be tolerated.

Reporting and assistance

Reporting and assistance

If any Resolve Personnel are approached by a Public Official, client or supplier representative, or any other person and is asked, directly or indirectly, to make a questionable payment or gift, the occurrence should be promptly and fully reported to manager or other personnel in a superior position, who in turn shall report such occurrence to the Chief Executive Officer of Resolve.