1. Zero-Tolerance Principle
Ory prohibits bribery, corruption, kickbacks, extortion, embezzlement, fraud, and improper influence in every location and transaction. No business objective justifies a violation.
2. Who Must Comply
This Policy applies to directors, officers, employees, contractors acting for Ory, agents, consultants, intermediaries, lobbyists, customs brokers, and other representatives. Relevant controls apply to partners and counterparties.
3. Prohibited Payments
No one may directly or indirectly offer, promise, authorize, give, request, or accept anything of value with corrupt or improper intent to obtain or retain business, secure an improper advantage, influence an official act, or reward improper performance. This does not prohibit lawful, properly documented, and reasonable commercial arrangements – such as bona fide discounts, competitive pricing, modest meals or hospitality, product demonstrations, or consultations – that are customary and are not intended to improperly influence a decision. Facilitation payments are prohibited except a payment strictly necessary to address an imminent threat to health or safety, which must be promptly reported and accurately recorded.
4. Government Officials
Interactions with officials, state-owned enterprises, political parties, candidates, public international organizations, military personnel, and their close associates require heightened review. Government status can be broader than expected.
5. Gifts, Hospitality, Travel, Donations, and Sponsorships
Gifts, hospitality, travel, donations, and sponsorships must be lawful, reasonable, infrequent, transparent, accurately recorded, and never intended to improperly influence a decision. Cash and cash equivalents are prohibited. Anything involving a government official, third-party travel, or unusually valuable or sensitive hospitality requires prior written approval from the Chief Compliance Officer at info@oryminerals.com.
6. Third Parties and Transactions
- Perform risk-based due diligence before engagement and periodically thereafter.
- Use written contracts defining a legitimate scope, reasonable and documented compensation commensurate with the services provided, appropriate audit and termination rights, and compliance duties.
- Apply enhanced review to unexplained commissions, offshore or third-party payments, cash demands, possible sham services, refusal to disclose ownership, and other circumstances that may indicate elevated risk. Legitimate cross-border payment arrangements must be documented, transparent, and approved through applicable controls.
- Apply enhanced review to permits, customs, government sales, agents, joint ventures, acquisitions, and high-risk jurisdictions.
7. Books, Records, Conflicts, and Fair Dealing
Transactions must be accurately and completely recorded. Undisclosed accounts and false descriptions are prohibited. Personnel must disclose actual or potential conflicts of interest and deal fairly with counterparties.
8. Advice, Reporting, and Non-Retaliation
Ask the Chief Compliance Officer at info@oryminerals.com before acting when uncertain. Report concerns through info@oryminerals.com. Ory prohibits retaliation for good-faith reporting or cooperation.
9. Investigations and Consequences
Ory may investigate suspected violations, preserve records, cooperate with authorities, and impose discipline up to termination. Contractual remedies may include withholding, audit, suspension, or termination.