Privacy & Anti-Bribery Compliance Policy | NAUMAC

Privacy & Anti-Bribery Compliance Policy

NAUMAC Privacy Policy

Thank you for visiting and reviewing our website privacy policy. This privacy policy applies to all NAUMAC webpages and was last updated the 28th of March 2018.

NAUMAC understands that your privacy is important. NAUMAC is committed to protecting your privacy and personal information you provide as you access and use materials on (the "Site"). In addition, information that you submit to NAUMAC in response to an email request for information or other outreach from NAUMAC, or through NAUMAC’s employment application processes, will be treated in accordance with this Privacy Statement.

NAUMAC may, in its discretion, amend this Privacy Statement from time to time. To ensure you are able to remain informed about the information we collect and how we use it, material changes to our statement will be reflected here. This Site may contain links to external sites which are not governed by this Privacy Statement. NAUMAC does not take responsibility for the privacy practices of any third party sites to which we link. We encourage you to review the privacy policies of any such sites before you submit information there.

Your acceptance of this privacy statement

Please read this Privacy Statement carefully. By browsing our website you agree to be bound by this Privacy Statement.

Information that we collect and how we use it

We sometimes aggregate demographic information, and the types of systems and browsers of users for internal purposes, so that we may better understand the Site’s user population, identify subject areas of interest, and determine whether the Site is designed to work with the computer settings of a majority of our visitors.

NAUMAC does not collect and share personal information as we do not ask our visitors to subscribe to our Site.

Contact details

Only from potential clients and applicants contacting us via our Site we collect e-mail addresses and/or telephone numbers. This information will be used for internal use only.

NAUMAC e-mail disclaimer

“The contents of your email and any attachment(s) are strictly confidential and are solely for the person(s) at the email addresses above. If you are not an addressee, you may not disclose, distribute, copy or use this email, and we request that you forward this email to and delete this email. NAUMAC B.V. accepts no legal liability for the contents of this email including any errors, interception or interference, as internet communications are not secure. Whilst NAUMAC B.V. and the sender have taken every precaution to prevent transmission of computer viruses, should this inadvertently occur we do not accept any liability.

At NAUMAC we respect your privacy and take protecting it seriously. The use of information collected by this email shall be limited to the purpose of our relation management only. If at any time you would like us to remove your contact information from our records, please contact us at . Please note that you may no longer receive job offers, announcements, invitations or newsletters if we remove your personal information”.


NAUMAC may use browser cookies on this Site to keep track of your visit to our Site. A "cookie" is a small amount of data that is sent from a Web server to your browser and stored on your computer's hard drive. Use of cookies may allow NAUMAC to provide a higher quality, more relevant, customer experience. We may also use cookies to track which areas of the web site are most popular with our users and to further NAUMAC's understanding concerning overall use of the site. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored on your computer. Please refer to your browser instructions or you can visit which will give you more information. Once you have given your consent to use cookies we shall store a cookie on your computer or device to remember this for next time. If you wish to withdraw consent at any time you will need to delete our cookies using your web browsers settings. Please be advised that certain sections or functionalities of the Site may be inaccessible to you if your browser does not accept cookies.

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. For this we have an information processing agreement with Google. Google does not process the entire IP-address, which anonymizes your IP. We also have turned off the option 'share information with Google'.

No further use is made of other Google-services in combination with Google-Analytics-cookiesYou may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more about Google Analytics, Google's privacy policy and opting out of its cookies please visit:

Links to other web sites

This website may contain links to other Web sites not operated by NAUMAC.

NAUMAC is not responsible for the privacy practices or the content of any non-NAUMAC web sites to which we link from the Site. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and sites not governed by our Privacy Statement. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.

Compliance with law

NAUMAC complies with all applicable privacy laws and regulations.

Contact us

If you have any questions about this Privacy Statement please write to:

NAUMAC Anti-Bribery Compliance Policy


Naum Holding B.V., NAUMAC B.V., their subsidiaries and associate companies, including joint venture companies (collectively, “NAUMAC”), are committed to compliance with all applicable laws, rules and regulations.

NAUMAC is committed to doing business with integrity. This means avoiding corruption of all kinds. It is the policy of NAUMAC to comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act (“UKBA”), and the local laws in every country in which we do business. These laws prohibit bribery of foreign government officials (broadly defined later in this policy), and with regard to the FCPA in particular, mandate that companies establish and maintain accurate books and records and sufficient internal controls. The UKBA also prohibits private sector (commercial) bribery.


This policy applies to all employees of NAUMAC, including officers and directors. In addition, NAUMAC will require third parties who represent NAUMAC (such as agents, consultants, and contractors) to conduct themselves in a manner consistent with this policy.

All employees and third parties should remain vigilant in watching for, avoiding, and reporting to the Legal Department any questionable transactions that may violate this policy.

Although this policy focuses primarily on compliance with the FCPA and UKBA, it is necessary to remain equally attentive to compliance with all applicable corruption laws, including the federal, state and local laws of each country in which NAUMAC operates. The FCPA, UKBA, and local corruption laws will be referred to collectively as “Applicable Corruption Laws” in this policy.

For the purposes of this policy, the term “government official” is broadly defined to include:

  • Any officer or employee of any government entity, department or agency
  • Any employee of a state or government-owned business, school, hospital or other entity
  • Any political party or official thereof
  • Any candidate for political office
  • A public international organization or any department or agency thereof (e.g., the United Nations, Olympic Organizing Committee, FIFA Committee, and World Bank)
  • Any person acting in an official capacity on behalf of a government entity

Employees of state-owned or state-controlled commercial enterprises (such as an oil company that is majority owned by a government) are considered government officials under Applicable Corruption Laws and this policy. It is important to keep in mind that even persons who are not deemed to be officials under local laws may still be considered government officials under the FCPA and UKBA. To be certain, employees should always consult senior management whenever there is a question as to whether an individual is a government official.

Prohibition on Bribery

Applicable Corruption Laws prohibit companies and their employees and representatives from (directly or indirectly) giving, promising, offering or authorizing payment of anything of value to any government official in order to obtain or keep business or to secure some other improper advantage. In essence, these laws prohibit the giving of anything of value to influence a government official’s actions. Prohibited payments include, but are not limited to, those designed to:

  • Induce the recipient to award a contract to NAUMAC
  • Obtain advantageous tax, immigration or customs treatment that would not otherwise be available to NAUMAC
  • Circumvent or cause non-enforcement of laws or regulations applicable to NAUMAC

The prohibition on bribery applies to the giving of anything of value, not only money. This includes but is not limited to providing business opportunities, favourable contracts, stock options, gifts and entertainment. Such payments are barred even if:

  • The benefit is for someone other than the party making the payment
  • The business sought is not with the government
  • The payment does not in fact influence the government official’s conduct
  • The foreign government official initially suggested the payment

The UKBA also specifically prohibits the offering or acceptance of corrupt payments and other advantages between private (non-government) persons and entities. Such conduct constitutes commercial bribery and is prohibited.

Facilitating Payments

Facilitating (or expediting) payments also are prohibited under this policy. Facilitating payments are small payments paid to foreign government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, providing police protection, providing telephone, power or water service or loading or unloading of cargo.

Although there is a narrow exception for facilitating payments under the FCPA, such payments are prohibited under the UKBA and the laws of many other countries. Therefore, in order to ensure compliance with all Applicable Corruption Laws, NAUMAC prohibits facilitating payments altogether, except for personal safety payments described below.

Except as provided herein, employees are prohibited from providing anything of value to any foreign official, regardless of rank; or to any person while knowing or being aware that all or a portion of it will be offered, given or promised (directly or indirectly) to a foreign government official.

Permitted Payments

Although this policy is intended to provide guidance, anti-corruption matters are not always clear and must often be addressed on a case-by-case basis. In all situations where there is a question, employees should consult senior management prior to taking action.


NAUMAC may pay for legitimate services provided to NAUMAC by a foreign government entity or government official, such as paying a government-owned utility company for electricity.

Gifts, Meals, and Entertainment

Under certain circumstances, it may be permissible to provide modest gifts or a meal or other entertainment to a government official as a social amenity. When deciding whether a gift is appropriate, employees also must take into account any past, pending or future business or administrative matters that are within the recipient’s realm of influence. The timing and context surrounding such gift or entertainment must be weighed in order to assess whether any particular gift or entertainment could be perceived to be a bribe.

Generally, gifts, meals and entertainment are permissible, provided that:

  • Hospitality offered on behalf of NAUMAC must be directly related to NAUMAC business, i.e. the marketing or sale of its services.
  • Hospitality in all cases must be reasonable in amount, must be offered in good faith only in connection with the promotion, demonstration or explanation of NAUMAC services or the execution or performance of a contract with a foreign government or agency thereof, and must be lawful under applicable local law.
  • There is no expectation that the gift, meal or entertainment is given in exchange for any return favour or business advantage from the government official (quid pro quo);
  • The gift, meal or entertainment is infrequent, reasonable, and proportionate in amount under the circumstances; and
  • The gift, meal or entertainment is lawful under Applicable Corruption Laws.
  • Unless otherwise approved by the Managing Director in writing, expenses for hospitality meals should not exceed the following EURO amount per person:
    • Breakfast: € 50,00
    • Lunch: € 200,00
    • Dinner: € 200,00
  • Refreshments unaccompanied by a meal should not exceed € 50,00 per person.
  • Frequency of hospitality must be carefully monitored, as the cumulative effect of frequent hospitality may give rise to the appearance of impropriety. Hospitality for any government official should not exceed twelve events in any calendar year. If additional hospitality is anticipated, prior written approval must be obtained from the Managing Director.
  • Cash gifts to government officials are not permitted under any circumstances. Per diem payments to government officials are also prohibited.
  • Promotional items of nominal value such as coffee mugs, calendars, or similar items, or items displaying NAUMAC logo that are distributed for advertising or commemorative purposes, or gifts of nominal value on customary holidays are permitted. “Nominal value” is € 100,00 or less.
  • In the event NAUMAC is responsible for the airfare or lodging expenses of a government official, itineraries and any other supporting documentation shall be maintained. In no case will payment or reimbursement be made directly to the government official incurring the expense; such payment or reimbursement shall only be made directly to the service provider (e.g. the airline) or the foreign government or agency involved. Expenses beyond what is reasonably necessary for the business purpose, including lavish accommodations or expenses for spouses and children, will not be approved. The Managing Director must approve all travel for government officials in advance of the trip.
  • In all cases that entertainment, gifts or travel expenses are approved, the expenses must be supported by receipts and accurately recorded in NAUMAC’s books.

Personal Safety Payments

Personal safety payments are permissible under this policy. A personal safety payment is a payment to avoid imminent physical harm. Personal safety payments do not include payments made in response to commercial duress, or in response to threats to commercial, financial or other interests. If confronted with a situation in which you believe that there is an imminent threat to your health or safety, you must use your best judgment in determining whether to make a personal safety payment. If you reasonably elect to make a personal safety payment, you will not be subject to discipline under this policy, but those payments must be immediately reported to the Legal Department. NAUMAC will not reimburse you for such payments.


Donations made to foreign-based charities are permissible, provided that all donations made by NAUMAC to foreign charitable organizations are permissible under the FCPA and local law, pre-approved by Managing Director and properly documented and transparent.

Political Contributions

Contributions to international political parties or committees or to individual politicians may only be made with the prior written consent of the Managing Director. Approved contributions must be made in accordance with the applicable law, and all requirements for public disclosure of such contributions shall be fully complied with.

Third Parties

Applicable Corruption Laws prohibit corrupt payments made directly by NAUMAC employees or indirectly through a third party such as a consultant acting for or on behalf of NAUMAC.

Under the FCPA, it is unlawful to make a payment of anything of value to any person, knowing that all or any portion of the payment will be offered, given or promised to a government official or any other person for a corrupt purpose. The term “knowing” includes conscious disregard, deliberate ignorance, and wilful blindness. In other words, NAUMAC and individual employees may violate the FCPA if we have “reason to know” or “should have known” that a third party will bribe a government official.

Under the UKBA, a company can be held criminally liable for bribes paid on its behalf by a third party anywhere in the world – even if NAUMAC had no knowledge of the bribe.

Accordingly, the most important step NAUMAC can take to protect itself from liability for improper payments made by third parties is to choose its business partners carefully.

NAUMAC will conduct appropriate due diligence and will exercise care in selecting such third parties by employing only reputable entities and will pay only reasonable compensation for the services provided.

NAUMAC will require third parties who represent NAUMAC to conduct themselves in a manner consistent with this policy. In addition, agreements with certain third parties must contain representations and warranties regarding the third party’s agreement to comply with Applicable Corruption Laws.

Red Flags

In evaluating potential third parties and during any relationship with them, NAUMAC employees must be conscious of any “red flags” that may be present or arise. A “red flag” is a fact or circumstance that serves as a warning signal that a third party may act corruptly. It is the responsibility of the employee that observes a red flag to refer the matter to the Legal Department or Ethics Hotline. A non-exclusive list of examples of red flags is below:

  • Rumours regarding unethical or suspicious conduct by an employee, marketing representative, consultant, agent, or other business partner, or by a government official
  • Unnecessary third parties, multiple intermediaries or suggestions to use a particular intermediary
  • Requests for payments to a second third party rather than the consultant or agent
  • Requests for payments in a country other than where the third party resides or performed the services
  • Requests for payments in cash
  • Requests for unusually large commissions or other payments, or payments that appear excessive for the service rendered
  • Requests for reimbursement of expenses that are poorly documented
  • Incomplete or inaccurate information in required disclosures
  • Refusal to certify compliance

Books and Records

NAUMAC has strict policies to maintain internal accounting controls and to comply with generally accepted accounting principles. All business information and transactions must be recorded accurately and timely in NAUMAC’s books and records, with the detail reasonably necessary to fairly reflect transactions.


Violations of this Policy will lead to disciplinary actions by NAUMAC against a violator, up to and including termination of employment. The enforcement of bribery laws around the world is increasing, both in terms of the number of enforcement actions and the severity of punishment. The consequences for violating bribery laws include fines and penalties for the individuals involved and for NAUMAC and can include prison terms for individuals involved in bribery, as well as serious damage to their reputation and career.

Report All Violations

Any individual who becomes aware of any violation of any law, rule or regulation or of this Policy, or who becomes aware of any suspicious activity or any “red flags”, has a responsibility to take action. Violations must not be ignored, hidden or covered up.

It is suggested that you contact one or more of the following:

  • An appropriate supervisor or a member of senior management;
  • NAUMAC’s Office Manager at +31 88 088 04 00 or write an e-mail to

NAUMAC will not tolerate retaliation against any individual for reports of any violation of any laws, rules or regulations or of this Policy that are made in good faith.