ANTI-BRIBERY POLICY

Quirch Foods does not tolerate bribery or corruption in any form

Quirch Foods’ reputation for conducting business lawfully and ethically is essential to our continued success. Our policy is to comply with the United States Foreign Corrupt Practices Act (FCPA) and all other applicable laws against corruption.

Anti-Bribery

Our policy prohibits all forms of bribery. This includes paying money, offers, gifts, promises to give, or authorizations to provide anything of value to any foreign official to secure a business advantage.

Accounting and Record-Keeping Provisions

We are required to maintain books and records that accurately and fairly reflect the transactions of the organization and are committed to maintaining a system of internal accounting controls, including periodic audits, sufficient to provide reasonable assurances that:

  • Management’s general and specific authorization executes all trades.
  • All transactions are recorded as necessary to permit the preparation of financial statements according to GAAP and maintain accountability of assets.
  • Assets can only be accessed with management authorization.
  • Recorded and actual assets can be compared.

Third Parties

Our policy establishes a due diligence compliance review and procedure for engaging sales representatives/agents and distributors. It requires those third parties to agree to comply with all applicable laws against corruption. Similarly, all logistics representatives must certify their compliance with the FCPA and other applicable anti-corruption laws. This policy applies to our agents, distributors, and joint venture partners.

Leadership

Our leadership team sets the tone at the top regarding our commitment to anti-corruption and compliance with our policy. We expect the utmost integrity and professionalism from our leadership team, which are examples to the rest of the workforce concerning conducting business in an ethical manner held to the highest standards.

Employee Training

We provide our employees training on anti-bribery laws and our policy, including onboarding training for new employees, periodic online training, and targeted in-person training sessions for smaller groups. We encourage our employees to promptly report any concerns regarding corruption to our legal department or our internal audit group.

FLORIDA | CORAL GABLES | MIAMI | ORLANDO | LAKELAND | PORT EVERGLADES SOUTH ATLANTIC | ATLANTA | GREENSBORO CENTRAL | HAMMOND | JACKSON | NASHVILLE | BIRMINGHAM | GRENADA | CHICAGO NORTHEAST | KING OF PRUSSIA TEXAS | DALLAS | SAN ANTONIO | HOUSTON | OKLAHOMA | McALLEN PACIFIC NORTHWEST | CLACKAMAS | TACOMA PUERTO RICO | SAN JUAN PHOENIX LOGISTICS & COLD STORAGE | WINTER HAVEN | ATLANTA HELMSMAN FREIGHT SOLUTIONS | CORAL GABLES, FL

UnitedHealthcare creates and publishes the Machine-Readable Files on behalf of Quirch Foods, LLC. To link to the Machine-Readable Files, please click on the URL provided: https://transparency-in-coverage.uhc.com/