Anti Corruption Initiatives

At Paragon Multi Services, we strive every day to earn the respect of our customers and shareholders based on the quality of our products and services as well as how we do business.

Paragon Multi Services faces a wide range of business and compliance risks, including those associated with corruption. Through Paragon Multi Services’s Enterprise Risk Management program, a continuous process conducted by all operating units across the PMS, we identify, assess and mitigate risks that may affect achievement of our performance objectives. Senior management is responsible for the implementation of mitigation plans, including those related to prevention of corruption. All allegations of corruption are promptly and thoroughly investigated, and, if verified, reported to senior management for disciplinary and corrective action and, where appropriate, to the Audit Committee of PMS’s Board of Directors.

Paragon Multi Services’s commitment to anti-corruption includes the following:

• Corrupt Payments: Paragon Multi Services conducts all of its business solely on the merits. We will not bribe anyone to obtain or retain business or secure any other advantage, nor allow anyone to do so for our benefit, in any market – public or private – anywhere. As a general rule, employees cannot seek or accept any payments from anyone doing business with or seeking to do business with PMS.
• Books and Records: A fundamental requirement of our Paragon Multi Services operating system is the maintenance of fully accurate and transparent books and records. All assets, liabilities and transactions must be promptly and accurately reflected, and no PMS employee must ever make a deliberately false or misleading entry – no matter how small or immaterial – in our books and records. PMS maintains a robust audit program to ensure that all of our businesses are upholding these non-negotiable requirements.
• Training: Every Paragon Multi Services employee receives annual ethics and compliance training from their supervisor. New employees complete ethics and compliance training courses in their first two years; two of these modules specifically address corruption risk.
• Reporting and Investigations: In managing risk, Paragon Multi Services is conservative and data-driven.

In standing by our principles and complying with our Code of Ethics and Company Policies, we fight corruption and support the global development of fair markets. Our success relies on abiding by our core principles – regardless of what might be seen as customary or acceptable in a given market.