Anti-Corruption Policy


This is a global policy (“Policy”) of Hunter Douglas Asia (“HDA”). It applies to you, in your capacity as an employee of any of the subsidiaries throughout the Asian Region.

HDA is committed to conducting its business activities with honesty and fairness. An important part of honoring that commitment is making sure that everyone at HDA, and everyone that represents HDA, upholds our standards of ethical business conduct.
This Policy applies to you, as an HDA employee, in your conduct of business. The Policy also applies to HDA’s Business Partners who sell our products, as well as other representatives and intermediaries who deal with government officials or private commercial parties on our products.
This Policy is designed to uphold our values and assure compliance with anti-corruption laws in all countries in which the Hunter Douglas Group operates, including not only the local laws of the Asian countries in which HDA operates, third-country laws in the case of exports outside the region and the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act which can have a broader extraterritorial reach based on a nexus such as payments in US dollars or involvement of senior management of Hunter Douglas based in the US or in some specific cases, in the UK or on acts by expatriates from the US or the UK working in the region.
There are severe financial and criminal penalties for violations of anti-corruption laws. For example, FCPA violations may result in millions (USD) in fines, as well as imprisonment for individuals, while violations of the UK Bribery Act carry unlimited fines and imprisonment. In addition, fines imposed upon employees, directors, officers and agents cannot be paid or reimbursed, directly or indirectly, by the Company.
If you fail to live up to the standards set forth in this Policy, you will be subject to disciplinary sanctions, up to and including termination. Our Code of Business Conduct reminds and encourages you to report any concerns without fear of retaliation. You will never be punished in any way for raising questions or reporting possible issues in good faith.
HDA Business Partners who fail to comply with the applicable standards set forth in this Policy will also be subject to actions that may include termination of our business relationship, as well as damages and other legal remedies.

The following terms and definitions apply to this Policy:

Agent” means any individual or firm authorized, whether formally or not, directly or via an intermediary, to act or represent that it acts on behalf of selling and or installing HDA's products and services;

anything of value” means cash, gifts (including gifts to family members), discounts on products and/or services not readily available to other customers, commission payments, stock shares, a promise to pay, loans, assumption or forgiveness of a debt, payment or reimbursement of expenses, personal favors, entertainment, meals, travel, political & charitable contributions, business opportunities, medical care, or an offer of employment for a government official or a relative of a government official;

HDA” means Hunter Douglas Asia, which as of the date of this Policy has the following subsidiaries:
HD (China) Holdings Company Limited HD Singapore Pte Limited
HD Architectural Products (Xi’an) Co. Ltd. HD India Private Limited
HD Architectural Products Terracotta (China) Co. Ltd. PT Hunter Douglas Indonesia
HD Architectural Products (China) Co. Ltd. HD Japan Limited
HD Architectural Products (Shenyang) Co. Ltd. HD Korea Limited
HD Architectural Products (ChengDu) Co. Ltd. HD (Malaysia) Sendirian Berhad
HD Architectural Products (Shenzhen) Co. Ltd. HD Manufacturing (Malaysia) Sdn Bhd
HD Window Covering Products (China) Co. Ltd. Hunter Douglas Taiwan Ltd.
HD Building Products (Beijing) Co. Ltd. Hunter Douglas (Thailand) Ltd.
HD China / Hong Kong Ltd. Hunter Douglas Vietnam Ltd.
Turnils-Mermet (Shanghai) Co. Ltd. HD Indochina Co. Ltd.
Turnils-Mermet Asia Sdn Bhd Blaze Manufacturing Company Ltd.
  Công ty TNHH Sản xuất Vinh Quang

Business Partner” means all distributors, joint venture partners, Agents, consultants and any other third party who act, or represent that they sell HDA’s products and services;

Facilitating Payment” means a small payment that is designed to secure or expedite a routine government action by a Government Official;

Government Entity” means an entity or business which is owned, controlled or affiliated with a government or a government organization;

Government Official” means:
  • Officers, employees or official representatives of any national, regional, local, or other Government Entity, including elected officials; or
  • Officers, employees or official representatives of companies in which a government owns an interest; or
  • Current candidates for political office at any level; or
  • Political parties and their officials; or
  • Officers, employees, or official representatives of public (quasi-governmental) international organizations, such as the World Bank, Red Cross, United Nations, International Monetary Fund, etc.
routine government action” means obtaining permits, licenses, or other official documents; processing governmental papers, such as visas and work orders; scheduling an inspection; providing police protection, securing mail pickup or delivery; getting utilities such as power or phones connected; loading and unloading cargo; moving perishable goods through customs; and actions of a similar nature;

you” means (a) you, in your capacity as an HDA employee, (b) all employees, directors and officers of HDA, and (c) all Business Partners of HDA and its subsidiaries worldwide, as applicable.

a. Conflicts of Interests 
Conflicts of interest (e.g. your receiving gifts from counterparties) is not covered by this Policy but rather by the Hunter Douglas Group Conflict of Interest Policy. Generally speaking, that policy prohibits you from receiving more than small gifts from counterparties, doing business on behalf of an HD company with counterparties with which you have financial or family ties as well as personal dealings with the counterparties.

b. General Standard
HDA strictly prohibits you from giving bribes of any kind. Accordingly, you are not permitted to give or offer anything of value to anyone improperly to gain or retain business or to obtain or retain a business advantage. The more detailed sections below set forth what gifts and entertainment are appropriate and what are improper. HDA makes no distinction between bribery of government officials and bribery of workers in other sectors. Both are unacceptable. HDA requires that all payments and receipts are recorded in HDA’s books and records in accordance with applicable accounting standards and legal requirements.

c. Payments
You may not make, offer, or facilitate a payment to anyone to win influence or gain or retain business or an improper business advantage. Payments that are improper if made directly by you may not be made indirectly (for example, through a relative, agent or dealer). Even if you are not certain that a part of a payment to a third party will be passed on as a bribe, you must not make or facilitate that payment if you believe that bribery will or is likely to occur. HDA prohibits Facilitating Payments unless the specific payment is confirmed in writing in advance and approved by the HDA controller as lawful. All Facilitating Payments must be accurately described and recorded in the appropriate accounting books and records of the relevant HDA entity. Failure to obtain advance written approval for, and accurately record any, facilitation payment, is ground for disciplinary action, up to and including termination.

d. Record-Keeping and Accounting Requirements
Anti-corruption laws generally require a company to maintain books, records and accounts in reasonable detail, accurately reflecting all transactions of the company regardless of value and maintain an adequate system of internal accounting controls.
If you believe that a payment has been or may be recorded improperly, you have a duty to report this immediately to the:
  • Business Unit CFO; or
  • Regional controller; or
  • The Hunter Douglas Group CFO
e. Gifts
In some locations, it may be customary to give token gifts to Business Partners with whom you are doing business on HDA’s behalf.
You may give a small gift if it (1) is not cash or a cash equivalent (e.g., gift cards, securities); (2) is not offered in exchange or as a reward for any action or inaction; (3) is permitted under both local law and the guidelines of the recipient’s employer; (4) comports with local custom; and (5) is presented with complete transparency and recorded on HDA’s books; and (5) the gift is not worth more than USD 500.

f. Entertainment and Travel
With respect to Government Officials, anti-corruption laws generally permit companies to pay for travel and accommodation expenses of a Government Official visiting a company site or other business-related location, provided that (a) the travel is for a legitimate business purpose, such as a meeting to discuss regulatory issues or to demonstrate company products; and (b) the expenses are reasonable given the seniority of the Government Official.
As a consequence, HDA requires that a Government Official Travel Acknowledgement (see Appendix) be completed in advance of any commitment to pay for travel or accommodation expenses for a Government Official. Completed, signed Acknowledgements must be sent to the Regional Controller. Travel cannot include side trips to non-business destinations, and HDA will not cover the expenses of family or friends.
With respect to Business Partners, business entertainment expense must be both ordinary and necessary, and meet either of the following two tests:
  • entertainment took place in a clear business setting, or the main purpose of entertainment was the active conduct of business, and you did engage in business with the person during the entertainment period, and you had more than a general expectation of getting some specific business benefit; or,
  • entertainment was associated with HDA’s business and the entertainment directly preceded or followed a substantial business discussion.
All expense must be fully documented with appropriate receipts and a complete description as to time, place, and type of entertainment; name title, and business affiliation of customers, suppliers, or other business partners entertained; and the business purpose of the entertainment. If entertainment was provided in a place not normally conducive to a business discussion (theater, sporting event, etc.), show the date, time, duration, place, nature, and participants in the related business discussion preceding or following the entertainment. The entertainment may not be such that offering the same will violate local law (e.g. meals with too many courses than allowed for Chinese officials).
Expenses for gifts or entertainment not allowed under this Policy are not reimbursable.

g. Political and Charitable Contributions
You may not make political or charitable donations (including sponsorships), whether in your own name or in the name of HDA, to obtain or retain business or to gain an improper business advantage. Any approved political or charitable contributions or sponsorships that HDA makes, must be allowed under local law, made to or for a bona fide political or charitable organization. This Policy does not restrict your personal support of any charitable or political organization in your own name.
To avoid even the appearance of impropriety, you must secure the prior written approval of the regional controller before making a political or charitable contribution on HDA’s behalf, or as a result of a request made to you in your role at HDA, other than as a result of charitable initiatives sponsored by HDA. Any connection of any Government Official to any organization receiving a proposed contribution must be identified.

h. Dealings with Third Parties and Business Partners
HDA’s commitment to compliance with anti-corruption laws extends to the activities of its Business Partners. You should be careful to avoid any situation involving a third party that might lead to a violation of any applicable anti-corruption laws. Both HDA and you can be held liable for improper payments made by HDA’s Business Partners to a third party on HDA’s behalf, or failing to prevent bribery by those acting on HDA’s behalf. HDA policy requires periodic due diligence reviews at the regional level for select Business Partners representing or acting on behalf of the Company.
First, new business partners who are expected to do a volume of business with HDA in excess of USD 5,000 per year, need to be screened by the Business Units Controller for PEP status, sanctions, and reputational risk.
Second, all business partners are required to sign the Vendor Letter of Declaration VLOD in the current form.
You must remain alert to certain suspicious circumstances, the more common types of which are listed as “Red Flags” below. These circumstances may indicate higher corruption risk:

Red Flags:
The Business Partner:
 appears from the screening through Refinitiv or another system to be a Politically Exposed Person (PEP), related to a PEP, related to or affiliated with a government contract official, or have a history of criminal convictions or on a sanctions list:
 resides outside the country in which the services are to be rendered; or
 was specifically requested or recommended by a Government Official; or
 refused to sign the Vendor Letter of Declaration VLOD and/or requests such wording to be deleted or amended; or
 provides incomplete or inaccurate information in due diligence disclosures; or
 requests payments to be made to a third party or a third-country bank account, or requests other unusual financial arrangements; or
 requests payment in cash; or
 requests that false invoices or other documents be created or prepared in connection with a transaction; or
 uses unidentified sub-agents or sub-contractors to assist in their work; or
 requests an usually high commission or success fee or appears to be earning an excessive dealer margin in relation to the services provided and the credit and other risk assumed; or
 requests a commission be paid before announcement of a contract signing or regulatory decision; or
 requests lavish entertainment, gifts, or travel in connection with negotiations; or
 requests reimbursement for poorly documented/questionable expenses; or
 does not have the relevant qualifications, organisational resources or staff for the services being provided.

If you encounter or perceive any of these Red Flags when considering a new Business Partner or working with an existing Business Partner, you should contact the regional controller.




1. 定義



HD (China) Holdings Company Limited HD Singapore Pte Limited
HD Architectural Products (Xi’an) Co. Ltd. HD India Private Limited
HD Architectural Products Terracotta (China) Co. Ltd. PT Hunter Douglas Indonesia
HD Architectural Products (China) Co. Ltd. HD Japan Limited
HD Architectural Products (Shenyang) Co. Ltd. HD Korea Limited
HD Architectural Products (ChengDu) Co. Ltd. HD (Malaysia) Sendirian Berhad
HD Architectural Products (Shenzhen) Co. Ltd. HD Manufacturing (Malaysia) Sdn Bhd
HD Window Covering Products (China) Co. Ltd. Hunter Douglas Taiwan Ltd.
HD Building Products (Beijing) Co. Ltd. Hunter Douglas (Thailand) Ltd.
HD China / Hong Kong Ltd. Hunter Douglas Vietnam Ltd.
Turnils-Mermet (Shanghai) Co. Ltd. HD Indochina Co. Ltd.
Turnils-Mermet Asia Sdn Bhd Blaze Manufacturing Company Ltd.
  Công ty TNHH Sản xuất Vinh Quang



• 国、地域、地方またはその他の政府団体における役員、職員、または正式な代表者
• 政府が権益を有する企業の役員、職員または正式な代表者
• 官職・公職候補者(官職・公職のレベルを問いません。)
• 政党およびその職員
• 世界銀行、赤十字、国際連合、国際通貨基金といった公的(準国家的)な国際組織の役員職員、または正式な代表者

「あなた」は、 (a) 取締役、役員、従業員を含むHDAで勤務するすべての者(b)HDAに関与するすべてのビジネスパートナーおよびその子会社を意味します。

2. 行動規範

a. 利益相反


b. 一般規範


c. 支払


d. 記録管理および会計要求事項

• 担当地域のCFO
• アジア地域経理責任者
• ハンターダグラスグループCFO

e. 贈答品

(1) 現金または現金同等物(ギフトカード、証券類など)に該当しない。
(2) 特定の行為、不作為の見返りとして提供されるものに該当しない。
(3) 現地法律並びに受領者の雇用者指針の下で許容されているもの。
(4) 現地慣習と適合し、完全かつ透明性を持った帳簿記録がされているもの。
(5) 価額が500米ドル以下であるもの。

f. 接待および出張


 (a) 移動に適法、正当な事業目的があること。(規制に関する協議、会社製品の実演を行うための会合など)
 (b) 政府公務員の地位を考慮して合理的な経費であること。

 (a) 事業を背景としていることが明らかな状況で接待が行われ、または接待の主たる目的が事業の積極的な遂行にあること。接待を行っている期間中に当該者との取引関係にあること。
 (b) 接待がHDAの業務と関連しており、業務関連の実質的な協議・打合せの直前または直後に行われること。


g. 政治・慈善上の寄付


h. 第三者およびビジネスパートナーとの取引


1. HDAと年間5,000米ドルを超える金額の取引を行うことが予想される新規のビジネスパートナーは、PEPの状態、制裁、風評被害の危険性に関して、担当地域の経理責任者による調査を受けなければなりません。

2. すべてのビジネスパートナーは、現行のベンダー(供給業者)同意書(VLOD)に署名することが求められます。


事業・ サービスの提供予定である国以外に居住している場合
ベンダー(供給業者)同意書 (VLOD)への署名を拒否した場合、または文言の削除または修正を要求してくる場合
不十分な 記録または疑わしき経費の精算を要求してくる場合