Anti-Bribery and Anti-Corruption

Ocean Air International (OAI) will not tolerate bribery or any form of corruption.

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action. It is illegal, and it is a breach of trust.

A bribe is an inducement or reward offered, promised or provided in order to gain a commercial, contractual, regulatory or personal advantage.

Corruption, bribery or attempted bribery is unacceptable. This applies whether offering a bribe, or accepting a bribe. It is against OAI core values of conducting business to the highest legal, moral and ethical standards. Bribery and corruption are covered by various international laws and statutes. These laws often require companies to have rigorous, pro-active measures in place to detect and prevent corrupt practices.

We insist that our service providers commit to legal and ethical behavior, and to refrain from doing anything that will harm the interests of our customers or the industry. We also ask our service providers to take steps to ensure they are fully informed of applicable regulations and will monitor their employees and business partners to ensure full and continual compliance.

Legal compliance

Our service providers will ensure that they are aware of all applicable laws countering bribery and corruption in all the jurisdictions in which they operate, and that they will obey and uphold those laws.

Ethical Behavior

As a demonstration of its commitment, we ask our service providers to pledge to take a zero-tolerance approach to bribery and corruption. Our service providers will act professionally, fairly and with the utmost integrity in all business dealings and relationships. This will apply wherever they operate.

Service Provider Code of Conduct

By agreeing and committing to ethical behavior as a service provider for OAI, undertakes to:

1.            Never engage in any form of bribery, either directly or through any third party.

2.            Never offer or make an improper payment, or authorize an improper payment (cash or otherwise) to any individual, including any local or foreign official anywhere in the world.

3.            Never attempt to induce an individual, or a local or foreign official to act illegally or improperly.

4.            Never offer, or accept, money or anything of value, such as gifts, kickbacks or commissions, in connection with the procurement of business or the award of a contract.

5.            Never offer or give any gift or token of hospitality to any public employee or government official or representative if there is any expectation or implication for a return favor.

6.            Never accept any gift from any business partner if there is any suggestion that a return favor will be expected or implied.

7.            Never facilitate payments to obtain a level of service which one would not normally be entitled to.

8.            Never disregard or fail to report any indication of improper payments to the appropriate authorities.

9.            Never induce or assist another individual to break any applicable law or regulation.


MS3 Supply Chain procedures as described here are reviewed on an annual basis in January of each year. This review is scheduled on the calendar of OAI quality manager for FIDI. The procedures are reviewed for relevance and effectiveness and updated as necessary.

Supply Chain monitoring takes place on alternate Saturday morning meetings at OAI. Agent performance is reviewed and remains a required topic.

Corrective actions if required are initiated at this time, or during the normal course of business. Corrective actions can take the form of a phone call to the supplier to discuss improvement required, or a communication from the Managing Director of OAI requiring the necessary change to improve performance, or adding the vendor to our Unapproved Vendors List.

i)             Avoid conflict of interest: Conflict of interest

We must avoid any relationship or activity that might impair, or even appear to impair our ability to make objectives and fair decision when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of OAI may conflict with our own personal or family interest because of the course of action that is best for is personally may not also be the best course of action for OAI. We owe a duty to OAI to advance its legitimate interests when the opportunity to do so arises. We must never is OAI property or information for personal gain or [personally take for ourselves any opportunity that is discovered through our position with OAI.

Here are some other ways in which conflicts of interest could arise:

  1. Being employed(you or close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with OAI.
  2. Hiring or supervising family members or closely related persons.
  3. Serving as a board member for an outside commercial company or organization.
  4. Owing or having a substantial interest in a competitor, supplier or contractor.
  5. Having a personal interest, financial interest or potential gain in any OAI transaction.
  6. Pacing company business with a firm owned or controlled by an OAI employee or his/her family.
  7. Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless equally available to all OAI employees.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the HR department.

ii)            Gifts, Gratuities and Business Courtesies

OAI is committed to competing solely on merit of our product and services. We should avoid any action that create a perception that favorable treatment of outside entities by OAI was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom OAI does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of OAI or customers, or would cause embarrassment or reflect negatively on OAI’s reputation.

iii)           Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our position at OAI. We should not feel any entitlement to accept and keep business courtesy. Although we may not accept unsolicited business courtesies that promote successful working relationship and goodwill with the firms that OAI maintains or may establish a business relationship with.

Employees who award contracts or who influence the allocation of business, who create specification that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from supplier when OAI is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain OAI business.

iv)          Meals, Refreshments and Entertainment

We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay the meal or entertainment, provided that:

  • They are not inappropriately lavish or excessive.
  • The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
  • The courtesy does not create the appearance of an attempt to influence business decision, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
  • The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his/her manager or co-worker or having the courtesy known by the public.

v)           Gifts

Employees may accept unsolicited gifts, other than money, that confirm to the reasonable ethical practices of the market place, including:

  • Flowers, fruit basket and other modest presents that commemorate a special occasion.
  • Gifts of nominal value, such as calendars, pens, mugs, cups and t-shirts (or other novelty, advertising or promotional items).
  • Generally, employees may not accept compensation, honor-aria or money of any amount from entities with whom OAI does or may do business. Tangible gifts (including tickets to sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management.

Employees with question about accepting business courtesies should talk to their managers or the HR department.

vi)          Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon OAI. An employee may never use personal funds or resources to do something that cannot be done with OAI resources. Accounting for business courtesies must be done in accordance with approved company procedures.

Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value provided that:

  • The practice does not violate any law or regulation or the standards of conduct of the recipients organization.
  • The business courtesy is consistent with industry practice, is frequent in nature and is not lavish.
  • The business courtesy is properly reflected on the books and records of OAI.

Anti-Bribery and Anti-Corruption check

Preventive Action: in order to prevent bribery and corruption in its amidst, OAI conducts quarterly close door meeting between top management and all department managers’ heads.

During meeting a through survey is conducted of all working of OAI conducted and analyses is made. If it was found that during work in the time duration certain aspect were found to be of misconduct, than the matter is separated for further inquiry.

Root Cause Analyses: if during one such audit it is found that certain aspect of the business is found of misconduct, than the committee further analysis the problem to help in identifying the cause and further to identify the employee that is responsible for such misconduct.

Corrective Actions: after the root cause and the person are identified Mr. Tabish Raza is asked to take necessary action according to the rules, which are:

If an employee is found to be guilty of bribery and corruption he/she is suspended for one month without pay and is issued a warning letter (leading to termination if found again involved in such practice), and also a written apology letter by the employee will be submitted to the committee, after his suspension period OAI anti-bribery and anti-corruption rules will be read to him by Mr. Tabish Raza and will be under observation till the next committee meeting in which his working practice will be analyzed, if no misconduct is found than the employee will be given all clear.

If the employee that is charged with misconducted is found to be an employee that is charged with such offence before he will be asked to immediately appear before the committee to explain himself, if the employee cannot convince the committee of his innocence or give very high reason which lead to his/her second misconducted the said employee will be terminated on spot.