The purpose of this Anti-Bribery Code of Ethics of GAPASH Integral Consulting is to prevent bribery and ensure compliance with the Anti-Bribery Management System (ABMS).

 

This Code applies to all managers and employees, regardless of their contractual status or nationality. It also extends to suppliers, consortium partners, contractors, and any third parties who represent or act on behalf of GAPASH. The Compliance Officer is responsible for overseeing compliance with this Anti-Bribery Policy and Code of Ethics and reports directly to the General Manager.

 

Guidelines

 

​1. BRIBERY:

 

a. The offering, promising, giving, or authorizing of direct or indirect payments, rewards, money, gifts, or any other benefit to public officials or their family members for the purpose of improperly influencing decisions, obtaining or retaining business, expediting administrative procedures, or securing undue advantages is strictly prohibited.

 

b. This prohibition applies to all employees and any third parties acting on behalf of GAPASH.

 

c. Employees are responsible for ensuring that third-party representatives comply with this Code. All third parties must have a written contract clearly defining the scope of services, compensation terms, and an explicit clause acknowledging compliance with GAPASH's Anti-Bribery Policy and Code of Ethics.

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​2. POLITICAL CONTRIBUTIONS:

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d. GAPASH shall neither make nor receive political contributions, gifts, hospitality, or benefits for the benefit of any political party, political organization, or candidate.

 

3. DUE DILIGENCE:

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e. GAPASH conducts due diligence on suppliers, employees, business partners, and associates as part of its business processes.

 

4. FINANCIAL AND NON-FINANCIAL CONTROLS:

 

f. GAPASH maintains accurate books, records, and accounts that transparently reflect all business transactions.

 

g. All transactions must be properly recorded in the company's financial statements.

 

5. ANTI-BRIBERY CONTROLS FOR BUSINESS PARTNERS:

 

​h. Third Parties:

 

• Third-party representatives must comply with this Policy through a written agreement specifying the services to be provided, compensation terms, and an explicit commitment to comply with GAPASH's Anti-Bribery Policy and Code of Ethics, or by signing the corresponding Anti-Bribery Commitment.

• EAll contracts shall include GAPASH's right to terminate the agreement in the event of any violation of this Code.

 

i. Consortiums:

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• Before entering into any consortium or business partnership, GAPASH shall conduct appropriate due diligence regarding the prospective partner's background, business practices, and anti-corruption controls.

• No consortium or partnership shall be established without prior investigation, verification, and final approval from the General Manager.

 

6. ANTI-BRIBERY COMMITMENT: 

 

j. GAPASH maintains a zero-tolerance policy toward bribery at all organizational levels and communicates this commitment to all business partners. Web page: http://www.gapash.com/

 

7. GIFTS, HOSPITALITY, DONATIONS AND FAMILY BENEFITS:

 

k. Gifts, Hospitality, and Gratuities:

 

• Cash payments, gifts, entertainment, hospitality, donations, or any other benefit that could improperly influence a business relationship or decision are prohibited.

• Employees may not accept money or gifts in exchange for awarding contracts or purchase orders to suppliers, subcontractors, or service providers.

• Employees may occasionally accept or provide promotional items bearing the company's logo with a modest value not exceeding USD 10 (or the equivalent in another currency), such as pens, keychains, or notebooks, when distributed during legitimate business events or conferences organized by GAPASH or its suppliers.

• Permitted promotional gifts may be retained by the employee or raffled among team members at the discretion of the relevant department.

• Gifts and hospitality must only be exchanged under appropriate circumstances and must never influence business negotiations or decisions. Therefore, gifts and hospitality may not be accepted during procurement or contract negotiations.

• Gifts must not be delivered to personal addresses.

• Any gifts received at GAPASH's offices or project sites shall be managed in accordance with the company's return or donation procedures.

• Business meals and hospitality offered to public or private officials are permitted only when they serve a legitimate business purpose and cannot reasonably be interpreted as an attempt to exert improper influence. The maximum allowable value is PEN 300.

• GAPASH may cover reasonable travel, accommodation, and related expenses when an individual's presence is necessary for legitimate business purposes. Such expenses shall not include family members or cash payments and must clearly reflect their legitimate business purpose.

 

8. CONFLICT OF INTEREST:

 

• Employees must avoid situations in which their personal interests conflict, or appear to conflict, with the interests of GAPASH.

• A conflict of interest exists when an employee uses their position within GAPASH to obtain personal, financial, or other benefits for themselves, their relatives, or related persons beyond the normal compensation provided by the company. A conflict also arises when an employee's personal interests interfere with their duty of loyalty to GAPASH.

• If a conflict of interest arises, the employee must immediately report it to their immediate supervisor and to the Compliance Officer so that appropriate measures can be taken.

 

9. REPORTING CONCERNS: 

 

l. The Compliance Officer is responsible for receiving inquiries, complaints, and reports regarding potential violations of this Code.

 

m. GAPASH encourages employees and business partners to raise concerns in good faith regarding suspected bribery or unethical conduct and guarantees confidentiality.

 

Ethics Hotline Email: lineaetica@gapash.com.pe

 

10. CONFIDENTIALITY:

 

n. Employees shall not disclose any confidential information obtained during the course of their employment or business activities with GAPASH unless authorized or legally required.

 

11. SANCTIONS:

 

o. Any violation of this Anti-Bribery Code of Ethics will be subject to an internal investigation and may result in disciplinary measures in accordance with GAPASH's Internal Work Regulations, including termination of employment, termination of business relationships, and legal action where applicable.