Represents and agrees that it shall be bound by and abide to all laws and regulations as well as
strictly comply with both the letter and spirit of the OECD Convention on Combating Bribery of
Foreign Public Officials, the UK Bribery Act, the U.S. Foreign Corrupt Practices Act (“FCPA”),
and any other applicable anti corruption laws as well as the Panalpina Code of Conduct.
Agrees that neither it nor its owners, directors, officers, employees, agents or subcontractors will
pay money, promise to pay money, authorize to pay money or offer or promise anything of value
to a person in a position of trust to unduly influence the judgment or conduct of that person.
There are no exceptions for small amounts or the so called “facilitation-“ or “grease-“ payments.
A person in a position of trust includes any public official, political candidate, political party, party
official and private sector employee or individual.
Warrants that none of its owners, directors, officers, employees, agents or subcontractors has
any personal relationships which might unduly influence the services provided by the Service
Provider.
Will systematically implement adequate measures and controls ensuring full compliance with
applicable anti-corruption laws and the commitments made in this document by Service
Provider’s subcontractors and agents, whenever performing services for Panalpina and/or
Panalpina’s customers.
Agrees to keep accurate books, accounts and records related to Panalpina business and that
Panalpina has the right to monitor compliance of the Service Provider. Service Provider further
agrees to make available for review its records and other documentation, and its owners,
directors, officers, and employees for interviews, in connection with any services provided to, or
on behalf of, Panalpina or its customers.
In the event Panalpina has in good faith reason to believe a breach of the requirements set out in
this form have occurred or may occur, Panalpina may suspend all further services and payments
related thereto, and/or terminate any contractual arrangements with Service Provider, in whole or
in part with immediate effect.