Ethics & Anti-Corruption Statement
OCFR-Gemba™ is committed to conducting business with the highest standards of ethics, integrity, transparency, and accountability. We believe that ethical conduct and strong anti-corruption practices are essential to building trust with our customers, partners, employees, and stakeholders.
This Ethics & Anti-Corruption Statement outlines the principles and expectations that guide our behavior and decision-making across all operations.
1. Our Ethical Principles
OCFR-Gemba expects all employees, officers, contractors, consultants, and representatives to uphold core ethical principles, including:
- Integrity – Acting honestly, fairly, and with moral courage
- Respect – Treating all stakeholders with dignity and professionalism
- Compliance – Adhering to applicable laws, regulations, and industry standards
- Responsibility – Taking ownership of decisions and their impact
- Transparency – Communicating clearly and openly when appropriate
These principles reflect our commitment to ethical conduct in every aspect of our business.
2. Zero Tolerance for Corruption and Bribery
OCFR-Gemba maintains a strict zero-tolerance approach toward corruption and bribery in all forms. We prohibit:
- Bribery – Offering, promising, giving, or receiving anything of value to influence a business decision
- Facilitation Payments – Payments to expedite routine government actions
- Kickbacks – Returning part of a transaction amount as an improper benefit
- Unauthorized Gifts or Hospitality intended to secure an improper advantage
All employees and representatives must comply with this requirement and refrain from any corrupt or corrupt-influencing behavior.
3. Compliance with Laws and Standards
OCFR-Gemba’s ethical and anti-corruption practices align with applicable laws and international good practices, including but not limited to:
- Anti-corruption and anti-bribery laws in jurisdictions where we operate
- Relevant guidance from international organizations
- Industry expectations for ethical conduct and corporate governance
We expect our stakeholders, partners, and third parties who act on our behalf to conduct themselves in a manner consistent with these standards.
4. Gifts, Entertainment, and Hospitality
Modest and transparent gifts, entertainment, or hospitality may be appropriate in some business contexts but must always:
- Be lawful and appropriate in nature
- Not influence or appear to influence business decisions
- Be documented and disclosed as required
Unsolicited gifts or hospitality that could improperly affect business judgment are not permitted.
5. Conflicts of Interest
OCFR-Gemba requires that actual or potential conflicts of interest are disclosed and managed appropriately. A conflict of interest may arise if personal interests interfere, or appear to interfere, with professional responsibilities.
Employees and representatives must promptly report any situation that could be interpreted as a conflict of interest.
6. Expectations of Third Parties
OCFR-Gemba engages with suppliers, contractors, consultants, and business partners who share our commitment to ethical conduct and anti-corruption compliance.
Where appropriate, OCFR-Gemba will:
- Include ethical expectations in third-party contracts
- Monitor third-party compliance
- Take corrective action if standards are breached
7. Reporting and Accountability
We encourage employees and stakeholders to report concerns, suspicions, or violations related to ethical conduct or corruption:
- Reports may be made confidentially and without fear of retaliation
- OCFR-Gemba has procedures in place to investigate reports objectively
- Corrective actions are taken as necessary following investigations
Reporting channels are maintained to support transparency and accountability.
8. Training and Awareness
OCFR-Gemba promotes ethical awareness and compliance through:
- Regular training programs
- Updates on relevant laws and policies
- Resources to help employees recognize and address ethical challenges
These initiatives help ensure that ethical standards are understood and embraced at all levels of the organization.
9. Governance and Oversight
Oversight of ethics and anti-corruption compliance is supported by senior management and relevant governance functions within OCFR-Gemba.
Responsibilities include:
- Reviewing and updating policies
- Ensuring compliance with applicable laws and internal standards
- Monitoring implementation of ethical controls
10. Limitations
This Ethics & Anti-Corruption Statement is provided for informational and compliance-alignment purposes only. It does not create contractual rights or obligations and does not modify terms in any legally binding agreements between OCFR-Gemba and its customers or partners.
11. Updates to This Statement
This statement may be updated periodically to reflect changes in regulatory expectations, industry standards, or organizational practices. Updated versions will be published on this page.
12. Contact Information
For questions about this Ethics & Anti-Corruption Statement or to report concerns: