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It is the Company’s policy to act in full accordance with all USA and foreign laws, rules and regulations applicable to it or the conduct of its business wherever located. Violation of laws, rules or regulations or compromise of the Corporation's ethical expectations could result in written reprimands or other disciplinary action, including termination and criminal or civil legal proceedings where applicable.


The Company is committed to the principles of fair competition in the purchase and sale of products and services. All purchasing decisions are to be based on normal commercial considerations, including quality, price, availability, service, HSE and other specific factors regarding the product or service. The Company will not seek, encourage nor tolerate special favors or arrangements that impact normal commercial relationships.


USA Bribery Act & Foreign Corrupt Practices Act (“FCPA”)

The USA Bribery Act prohibits improper payments to government officials and to others who are not government officials. The FCPA is a U.S. law that prohibits offering, giving or promising to give anything of value to a non-U.S. government official to obtain or retain business, or obtain any improper business advantage. It is the policy of the Company that all directors, officers, employees and others who represent the Company comply with the FCPA, and that we keep accurate records of all transactions involving government officials, regardless of the amount involved.  


Foreign officials are defined as:


• Any officer, employee or other person acting for, or on behalf of, a “public international organization” (such as the World Bank, the International Monetary Fund, or the Inter-American Development Bank)

• Any person acting in an official capacity or on behalf of any such government or governmental department (including government-owned companies, such as national oil companies, or NOC’s)

• Any officer or employee of a government.


Under anti-bribery rules, excessive hospitality including travel, lodging, meals or entertainment can also be considered a bribe. Directors, officers or employees should always consult the Company policy before giving any form of gift to a government official.



The Company periodically engages the services of Agents who may interact with customers and vendors on the Company’s behalf. Illegal or improper actions of Agents can have serious and detrimental consequences for the Company and it is therefore essential that Agents understand and comply with the requirements in this policy and all applicable laws. Before an Agent can perform any services for the Company, the Agent must, as necessary:

• Undergo a due diligence background.

• Sign a written agreement which includes standard requirements relating to USA anti-Bribery and FCPA compliance.



The Company requires compliance with all applicable import and export control laws and regulations of country in which the company conducts its business.