RAI Amsterdam B.V. Integrity Policy

RAI Amsterdam B.V. ("RAI") aims to do business fairly and ethically. Its integrity policy contains the principles which the company applies in its efforts to ensure that all its activities are conducted in a professional, honest and ethical manner. RAI applies a policy of zero tolerance in matters relating to bribery and corruption.

The integrity policy is applicable to all people who work for RAI either as employees or in some outside capacity and to all legal relationships between RAI and third parties such as hirers, organisers of or participants in events, and suppliers or subcontractors. Breaches of the integrity policy may be severely punished. Depending on the circumstances this may involve disciplinary measures, including in the worst cases termination of employment for employees and termination of the agreement with RAI in the case of outside contractors. In all cases the matter may also be referred to the criminal justice or regulatory authorities concerned.

No bribes or facilitating payments may be accepted or offered
It is strictly prohibited either directly or indirectly to offer or accept bribes and to make or arrange for facilitating payments to government officials in order to obtain or expedite acts or services of the authorities (irrespective of whether such payments are customary in a particular country).

Gifts, entertainment and hospitality
It is strictly prohibited to offer or accept gifts, entertainment or hospitality in dealings with customers or potential customers such as hirers, organisers of or participants in events, or suppliers or subcontractors and government officials, unless such gifts, entertainment or hospitality are of a clearly business-related nature and comply with the integrity policy and the related internal policy guidelines on the offering or receiving of invitations and/or gifts.

Charitable and political donations
It is strictly prohibited to make donations to charitable organisations or political parties, including facilitating payments, with a view to obtaining a commercial advantage.

Accounting records
RAI has in place an accounting and internal audit system that records the commercial reasons for each payment to third parties. All entertainment and hospitality expenses and costs of business gifts incurred for the benefit of a third party must be submitted for approval in accordance with the policy on expenses and must describe the reason for the specific expenditure in question. All bills, invoices, memoranda and other documents and records relating to relations with third parties such as customers, suppliers, sub-contractors and other business contacts must be drawn up and updated meticulously and exhaustively.

Compliance checks and reporting
RAI checks compliance with its integrity policy. All employees have a duty to immediately report a breach or suspected breach of this policy to their superior or, if they consider that this would be undesirable, to the confidential counsellor, in accordance with the RAI whistleblower policy.