Anti corruption- and fraud policy


EMS has drawn up this anti-corruption and fraud policy to ensure that it is clear how EMS can ensure that its activities, both in the Netherlands and abroad, cannot in any way be associated with corruption and / or fraud. . EMS does not tolerate any form of corruption or fraud.

To prevent fraud, we screen our customers, our employees and the companies we work with.

There can be large differences in the degree of corruption within a country. That is why we are extra vigilant for our foreign activities and take into account the level of corruption in a country in question and take (extra) measures where necessary.

This policy does not provide enough scope to describe all forms of corruption. If there is any doubt about EMS’s anti-corruption and fraud policy, please contact our Compliance Officer Gerrit Kuiper ( ) or one of the other EMS executives.


What is fraud?

By fraud EMS means the deliberate passing on of incorrect information or by withholding certain information. This also includes forgery. The purpose of fraud can be business as well as private gain.


What is corruption?

Corruption is a collective term for all kinds of cases in which someone misuses his / her position for personal and / or business gain. Among other things, bribery and extortion fall under this heading. Often corruption is accompanied by other criminal acts, such as forgery or money laundering.


What is bribery?

Bribery falls under the heading of corruption and aims to have the bribed person do or fail to do something that gives the briber unfair advantages. Examples in which this can take place are giving gifts, services, relationship management or making certain promises. Bribery can take place at both an official and private level (for example, a civil servant, politician or (private) person can be bribed or bribed). Different forms of bribery are:

  • Bribes/kickbacks: hidden transactions to get things done. The payment in itself is wrong, so the manner in which is no longer relevant.
  • Kickbacks: a form of kickback that is paid to influential individuals in an organization in exchange for benefits. The compensation is often determined in advance and is approved by both parties. So this is not directly a single bribe, but a conspiracy between both parties.
  • Facilitating payments: unofficial (small) payments to, for example, a government official to speed up or facilitate an official (and often routine) action. In this form of bribery, money is asked for a level of service that someone would simply be entitled to under normal circumstances.


Which rules does EMS follow?

We work with the applicable laws and regulations in the field of corruption, such as the Criminal Code (Netherlands), but also the international UK Bribery Act (United Kingdom) and the Foreign Corrupt Practices Act (United States).

Because participating in corruption is punishable for both employees and the entire organization, and this can seriously damage the reputation and finances of EMS, anyone who does business for, on behalf of or with EMS will never:

  • Promise, offer, give, solicit or expect a bribe or other improper advantage, directly or indirectly, to or from any third party (person or entity);
  • Participate in facilitation payments.

If an employee (or anyone else who works for, on behalf of or with EMS) discovers bribery or corruption, he / she will immediately contact his / her supervisor and the Compliance Officer will be notified immediately.


How does EMS prevent corruption and / or fraud?

  • By only entering into contracts with reference to anti-corruption and fraud provisions.
  • By making it clear (publicly) to parties that we do not cooperate in any form of corruption and / or fraud.
  • By cooperating with embassies abroad.
  • By making clear agreements in advance, making it clear in advance which services will be provided under which circumstances.
  • By keeping a transparent administration.