Criminal Compliance Policy
The Criminal Compliance Policy develops the provisions of the MILLER-INGRAM Code of Ethics and Conduct , mainly its sections 5 and 6, and, consequently, is linked to its ethical values, ratifying MILLER-INGRAM's firm will to maintain a respectful conduct both with the norms and with ethical standards and establishing, to this end, its framework of principles and rules of conduct of obligatory compliance in criminal matters, aligned with MILLER-INGRAM's determination not to tolerate within itself any conduct that could constitute a crime.
The Criminal Compliance Policy aims to strengthen the compliance system, promoting a corporate culture of ethics and integrity, and zero tolerance regarding criminal risks, and is part of the MILLER-INGRAM regulatory body, intended to prevent, detect and respond to any criminal conduct that may entail criminal liability for the legal entity, as well as economic and/or reputational damages.
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In this regard, MILLER-INGRAM expresses its firm commitment to establishing reasonable and proportional mechanisms for the purpose of its activity, which guarantee strict compliance with current legislation, including, as it could not be otherwise, that of the sanctioning and criminal sphere, and especially in the fight against fraud and corruption, prohibiting them in any of their forms.
MILLER-INGRAM thus shows its opposition to being able to benefit in any way from unethical behaviour, and even less so from behaviour that could constitute a criminal offence..
Therefore, the maximum commitment of the Administrative Bodies / Senior Management, and of the rest of the Members of the Organization, as well as the Business Partners (clients, suppliers, collaborators, advisors, etc.), is required to comply with its provisions.