ETHICS &INTEGRITY
SORC Defence maintains an uncompromising commitment to ethical conduct, anti-bribery compliance, and corporate integrity across all jurisdictions of operation.
Operating in the defence sector demands the highest standards of ethical conduct. SORC's ethics and integrity programme is built on three foundational statutes — the Canadian Corruption of Foreign Public Officials Act (CFPOA), the US Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act 2010 — and is reinforced by internal policies, training, and a zero-tolerance enforcement posture.
ANTI-BRIBERY FRAMEWORKS
Canada
Corruption of Foreign Public Officials Act
The CFPOA (SC 1998, c. 34) prohibits Canadian persons and entities from bribing foreign public officials to obtain or retain a business advantage. Enforced by the RCMP. Applies to all SORC personnel and associates regardless of where the conduct occurs. Penalties include up to 14 years imprisonment and unlimited fines. SORC maintains a CFPOA-compliant anti-bribery programme including due diligence on all intermediaries and agents.
United States
Foreign Corrupt Practices Act
The FCPA (15 USC § 78dd-1 et seq.) prohibits the payment of bribes to foreign government officials by US persons, US companies, and foreign companies listed on US exchanges. Jointly enforced by the DOJ and SEC. SORC's transactions involving US-origin articles or services are conducted in full awareness of FCPA obligations, including accounting and record-keeping provisions.
United Kingdom
UK Bribery Act 2010
The UK Bribery Act 2010 is among the most stringent anti-corruption statutes globally, criminalising active and passive bribery, bribery of foreign public officials, and — uniquely — the failure of a commercial organisation to prevent bribery. SORC applies Bribery Act standards to all transactions with a UK nexus, including UK-origin equipment and UK-registered counterparties.
ANTI-BRIBERY PROGRAMME
Tone from the Top
Senior leadership sets and enforces a zero-tolerance posture on bribery and corruption. No business opportunity justifies a compliance violation.
Risk Assessment
SORC conducts periodic bribery risk assessments covering jurisdictions of operation, counterparty profiles, transaction types, and intermediary relationships.
Due Diligence
All agents, intermediaries, consultants, and joint venture partners are subject to enhanced due diligence including ownership verification, PEP screening, and reference checks before engagement.
Gifts & Hospitality
A formal gifts and hospitality policy governs the giving and receiving of anything of value. All gifts above a de minimis threshold are recorded and approved. No facilitation payments are permitted under any circumstances.
Training & Awareness
All personnel and associates receive anti-bribery training appropriate to their role and risk exposure. Training is refreshed annually and upon onboarding.
Reporting & Whistleblowing
SORC maintains a confidential reporting mechanism for concerns about potential bribery or corruption. No retaliation against good-faith reporters is tolerated.
POLICY COMMITMENTS
Zero Tolerance
SORC will not engage in, facilitate, or condone bribery or corruption in any form, in any jurisdiction, under any circumstances. This applies to direct payments, facilitation payments, gifts, hospitality, and any other benefit intended to improperly influence a decision.
Intermediary Controls
No agent, broker, or intermediary is engaged without satisfactory completion of SORC's due diligence process. Intermediary agreements include mandatory anti-bribery representations, audit rights, and termination provisions for non-compliance.
Conflicts of Interest
All personnel and associates are required to disclose actual or potential conflicts of interest. Undisclosed conflicts are treated as a disciplinary matter. SORC does not engage with counterparties where a conflict cannot be adequately managed.
Accurate Books & Records
SORC maintains accurate books and records of all transactions, payments, and expenses. No off-book accounts, slush funds, or undisclosed payments are permitted. Records are subject to periodic internal review.
Ethics & Compliance Contact
To report a concern, request a copy of the firm's anti-bribery policy, or discuss compliance obligations on a specific transaction, contact the firm directly.
[email protected]