Connecting With What’s Right

We Don’t Tolerate Bribery or Corruption

At Panduit, we believe in doing business with integrity. Our success is the result of quality work and smart solutions, not underhanded deals, bribes, or other illegal arrangements.

A little cash on the side or an off-the-books favor might seem beneficial in the short term. But corruption carries costly legal, financial, and reputational risks for individual employees and Panduit.

Never offer or accept bribes, kickbacks, or other kinds of improper payment from customers, business partners, suppliers, or government officials.
Engage with ethical business partners to ensure third parties and intermediaries are aware of and comply with our Anti-Corruption Policy.
Make sure to keep thorough, accurate, and honest records of all financial transactions.
Any request for a “facilitation payment” must be reviewed and approved by the Chief Compliance Officer or the Legal Department.
Remember that failure to report bribery or other illegal activities may itself be a violation of this Code and the law, so report known or suspected corruption immediately.

What could bribery look like?

Cash or cash equivalents like gift cards, stocks, bonds, or cryptocurrency.

Inappropriate or extravagant gifts or entertainment, including paying for travel expenses.

Charitable donations, political contributions, or personal favors.

Loans or favorable financial terms or discounts that are not readily available to others.

Can we talk?

A sorely needed shipment of supplies is being held up in customs. The official I’ve been working with suggested paying an “expedite fee” to speed up the process. Is this legal?

It’s hard to tell. This could be a legitimate, legally sanctioned example of a facilitation payment, or it could be an attempt by the customs official to solicit a bribe. You should report the request to the Chief Compliance Officer and allow them to make the determination.

A relatively new supplier whose business is based entirely in North America recently requested that payments start going to an account based in Asia. When I asked why, she said, “That’s just how we’re doing things now.” Should I be concerned?

Yes, you should be. Not only is this a sudden and unexplained change in the supplier’s normal payment procedure, but it also involves an overseas financial institution with no logical connection to the supplier. You should report this change to a manager or the Legal Department.