In some circumstances third parties with whom we have a business relationship or which act for us (“Third Parties”) can put Stora Enso at risk of criminal liability if they bribe another person to obtain or retain business or a business advantage for Stora Enso.
The process in this Section 6 must be followed when engaging any new Third Party or when renewing the contract for any existing Third Party.
Follow the steps below to identify whether a Third Party is a Critical Third Party:
For Critical Third Parties with long or revolving contract terms, due diligence needs to be repeated every 12 months for high risk parties, and every 24 months for medium risk parties. You will receive system notification 30 days before such time is due.
During mergers and acquisitions, the potential entities that Stora Enso may acquire or merge with may present Corruption risks if we do not take adequate procedures. A joint venture partner could also present Corruption risks if they perform services on behalf of Stora Enso and/or the joint venture. Therefore the “M&A Guideline” or its equivalent states that a risk assessment and due diligence must be performed as part of the acquisition analysis considering bribery, as well as other compliance risks.
The M&A compliance due diligence questionnaire can be found HERE and an example of anti-bribery representations which should be considered for inclusion in a shareholders agreement can be found HERE.
