It is our policy to conduct our business in accordance with all applicable laws, rules and regulations, with honesty and integrity, in a manner which demonstrates respect for local cultural and ethnic customs, and with a strong commitment to the highest standards of ethics. We demand high standards of integrity and sound ethical judgment from our personnel at all times. As you read the more specific policies below, please keep in mind these high standards and your obligations as a part of the Summit family.
The FCPA is a US federal law enacted in 1977, prohibiting companies from paying bribes to foreign government officials and political figures. Companies violating this law by paying bribes are subject to criminal and civil actions, which can result in fines, suspension, and exclusion from government procurement contracts, while the employees and directors can be subject to prison sentences.
The Act’s provisions also apply to foreign companies and nationals taking part in any such act while doing business in the U.S. The Department of Justice is responsible for enforcing the anti-bribery provisions, as it pertains to domestic as well as foreign companies. The Securities and Exchange Commission (SEC) is responsible for civil enforcement of the anti-bribery provisions of the FCPA.
Summit ESP Employees receive regular training on anti-bribery laws and certify that they understand and will follow corporate policy. Summit Employees are also informed on the proper procedure and contact channels for guidance and or to report possible violations.
Third party relationships (joint venture partners and agents) are required to verify their compliance with anti-bribery laws.
Summit ESP has developed comprehensive due diligence procedures to investigate joint venture partners, agents and targets of prospective mergers and acquisitions. Finally, Summit ESP monitors current records to maintain that individuals do not hold a political office or have close relationships with government officials or organizations.
Summit ESP holds its suppliers to high standards, requiring a supplier qualification and due diligence process to be conducted before a supplier is set up. Key inventory suppliers are evaluated quarterly, and are expected to maintain an acceptable on time performance. Key inventory suppliers are also expected to maintain a nearly 100% quality performance rating. Nonconformance occurrences will be collected and analyzed using Summit’s Abby system. When a Key Inventory Supplier falls below the performance rating, the supplier must complete our Supplier Corrective Action Form. Continued failure to meet the established performance ratings will result in the supplier losing its Approved Supplier Status.