Anti-Bribery and Corruption Policy
Introduction
Rilex Energy is committed to conducting all business in accordance with the highest ethical and legal standards. In compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and other applicable state and federal laws, this Anti-Bribery and Corruption Policy outlines our zero-tolerance approach to bribery and corrupt activities.
The FCPA makes it unlawful for certain classes of individuals and entities to make payments to foreign government officials to assist in obtaining or retaining business. It also includes provisions related to internal controls and accounting transparency.
This policy applies to all employees, officers, agents, and third-party partners of Rilex Energy in the U.S. and abroad.
Corporate Liability Under the FCPA
The FCPA holds companies strictly liable for corrupt actions taken by employees, subsidiaries, agents, or intermediaries acting on the company’s behalf. Intent to violate the law is not required to impose liability.
Violations can result in:
- Criminal fines for corporations and individuals
- Imprisonment (up to 5 years per offense)
- Civil penalties, injunctions, and compliance monitoring
- Disqualification from public contracts or debarment
Additionally, reputational damage from FCPA investigations can result in serious long-term business losses.
U.S. Regulatory Expectations (SEC & DOJ)
While the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) enforce the FCPA, broader compliance requirements include:
- Effective internal controls to detect and prevent bribery
- Clear anti-corruption policies and procedures
- Regular employee training and risk-based due diligence
- Accurate books and records
Leadership & Commitment
Rilex Energy’s leadership, including its Board of Directors, upholds a zero tolerance policy for bribery or corrupt conduct, whether direct or indirect. Compliance with this policy is mandatory.
Due Diligence & Risk Assessment
We conduct enhanced due diligence on all third parties, including clients, sellers, intermediaries, and government officials. This includes:
- Background checks
- Anti-corruption screening
- Country-specific risk evaluations
Due diligence must be documented and updated regularly. Particular attention is paid to:
- Politically Exposed Persons (PEPs)
- Third parties in high-risk jurisdictions
- Red flags such as cash-only deals, off-record transactions, or excessive commissions
High-Risk Areas
Rilex Energy assesses bribery and corruption risk across the following:
- Procurement & contract negotiation
- Government licensing or permits
- Large-scale commodity trades
- Partnerships and joint ventures
- Operations in high-risk regions
Prohibited Conduct
The following activities are strictly prohibited:
- Offering, promising, or giving anything of value to a public official or private party to influence business decisions.
- Accepting, soliciting, or receiving bribes or kickbacks in any form.
- Making facilitation or “grease” payments to expedite routine governmental actions.
- Failing to report known or suspected bribery.
Third-Party Agents and Representatives
All third parties acting on behalf of Rilex Energy must:
- Comply with this policy and the FCPA
- Be subject to formal approval by senior management
- Undergo documented due diligence
- Operate under written contracts with anti-bribery clauses
Gifts, Hospitality, and Entertainment
While business courtesies may be part of relationship-building, they must be:
- Reasonable in value
- Infrequent
- Not intended to influence a decision
All gifts and entertainment must be logged and approved by the Compliance Officer. Cash gifts are strictly prohibited.
Client Entertainment, Benefits, and Expenses
Expenses for clients must:
- Serve a legitimate business purpose
- Be pre-approved by a Director or the Compliance Officer
- Be documented and reported accurately
Monitoring & Reporting
Rilex Energy will regularly monitor compliance through:
- Internal audits
- Financial reviews
- Whistleblower protections
Employees must report any concerns to the Compliance Officer or anonymously through the Company’s whistleblowing channel. Retaliation against whistleblowers is strictly prohibited.
Training
- All employees will receive annual training on anti-bribery and FCPA compliance
- The Compliance Department maintains all training records and will distribute updated materials as needed
Enforcement & Disciplinary Action
Violations of this policy may result in:
- Termination of employment
- Termination of contracts with third parties
- Civil and criminal penalties under U.S. law
Questions & Compliance Contacts
For questions about this policy or to report a concern:
Compliance Department – Rilex Energy
📧 support@rilexenergy.com
📞 Canada: 1-800-407-4739 or +1 (403) 921-6035
📞 USA: +1 (754) 222-2470
Rilex Energy is committed to ethical business practices in every transaction. We connect buyers and sellers — and everyone wins.
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