TML SOP No: XXXXXX

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Document Status Draft Revised Authorized Invalid

Transmarine Logistics Asia PTE Ltd (TML)

Standard Operating Procedure

TML
Anti-Corruption & Anti-Bribery
SOP Number Version Last Updated

XXXXX 4 01 Aug 2018

Valid From: 01 August 2018 Department: Operations

Valid Till: 01 August 2021 Division: TML

Authorization Matrix
Prepared By Designation Department Signature Date
Rahid
Senior Manager Strategic Planning
Chowdhury
Reviewed By Designation Department Signature Date

Htet Htet Aung General Manager Finance and Admin

Approved By Designation Department Signature Date

Sk Al Emran Country Head TML

Distribution List
Position Role

Director
Head of Operations
Head of Quality Assurance

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 TML SOP No: XXXXXX
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1. Purpose:

Generally certain corruptive activities occur when regulatory policies are not followed properly.
This document has all the list of guidelines that TML plans to follow to avoid such occurrences.

2. Scope:

This particular procedure covers all sorts of anti-corruption activities related to products
distributed by this company itself.

This Policy applies to all employees in TML, directly or indirectly connected.

This Policies are globally standardized. In some countries, more stringent applicable laws and
regulations supersede the principles set out in this Policy.

3. Archival Period:

The master copy of this SOP has to be archived at TML Head Office (DHO) for three (3) years
with acknowledgement record sheet. After the date of expiry, one original copy of this SOP has
to be preserved at DHO.

4. Responsibility:

Sl. Position Responsibility

Ensure that appropriate systems and resources are
4.1 Director
incorporated to prevent corruption and bribery.

Ensure validated monitoring system throughout the

organization.
4.2 Head of Operation
Strictly maintain a monitoring system to follow anti-
corruption & anti-bribery policies.

Arrange proper training for people involved in the

organization.

Ensure periodic inspection, reporting and follow-up

Head of Quality Assurance
4.3 Corrective and Preventive Action (CAPA).
and Compliance
Validate every preventive measure and process to maintain
this SOP.

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 TML SOP No: XXXXXX
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5. Procedure:

a) TML has zero tolerance policy for any sorts of bribery or form of corruption. Bribery is
committed when something of monetary or financial benefits is offered. Corruption is the result
of some sort of non-disciplinary actions or bribery which is considered illegal, immoral and last
but not the least, unethical.

b) No one is allowed to offer, propose, give or indirectly authorize anyone else to bribe.

c) No one is allowed to receive, be influenced, solicit or agree to receive a bribe.

d) No third parties involved are allowed to give or receive or influence bribery.

e) If someone is involved in a situation where bribery is being induced, he/she is advised to

immediately report that incident to his/her line manager.

f) All payments to the other parties involved must be made through TML approved procedures. A
substantial document for each transaction like for example banks transfer records, cheque,
cards must be maintained.

g) If third parties are allowed to make may make payments on TML’s behalf in their own business
purposes, proper documentation is to be provided.

h) No unnecessary payments be made to any third party in which breaches TML’s approved limit.

i) TML Disciplinary action on breach of policies: When the policy is not followed properly and
the employee is found to be responsible, TML’s employee code of conduct and employment
principles are to be followed to take necessary action.

6. References:

6.1 WHO Good Distribution Practices Annex- 5

6.2 Code of Pharmaceutical Marketing Practices-DGDA

7. Document History:
Description Author Date Version

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