Polaris is committed to being in full compliance with all applicable anti-bribery and anticorruption statutes in the those jurisdictions in which it operates, including but not limited to Canada. Polaris has no tolerance for any instances of bribery or corruption in any of its interactions with public officials and any such activities are strictly prohibited in any form. This prohibition also covers direct acts of bribery such as offering, approving, accepting, or otherwise authorizing a bribe or indirectly doing so through a third party. Gaining any unfairly obtained business advantage is also strictly prohibited.
To this end, Polaris has a global Anti-Bribery and Corruption Policy (the ?ABC Policy?)4. This ABC Policy applies to all of Polaris, its subsidiaries, employees, Board and any third party that performs services on behalf of Polaris or acts on behalf of Polaris. Annually, both the Board and Senior Officers sign off their acceptance and acknowledgement of this policy.
In addition to the requirements set out in the ABC Policy, Polaris further requires that enhanced Integrity Due Diligence procedures be conducted on select higher risk Third Parties in accordance with Polaris? Working with Third Parties and Integrity Due Diligence Protocol. Similarly, these enhanced Integrity Due Diligence procedures may also be required for prospective or current employees if they are former public officials.
