1. PURPOSE

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At ED4S, we are committed to conducting our business with the highest standards of integrity, transparency, and ethical behavior. 
We maintain a zero-tolerance approach to bribery, corruption, kickbacks, and all forms of improper influence, whether in Canada or abroad. 

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This policy outlines our expectations for ethical conduct in all interactions with clients, partners, suppliers, contractors, and public officials. It is aligned with Canadian laws and internationally recognized anti-corruption frameworks. 
 

2. SCOPE

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This policy applies to: 
 

• All employees and contractors of ED4S 

• All third-party partners, suppliers, service providers, and consultants 

• Any individual acting on behalf of ED4S in Canada or internationally
   

All individuals within this scope must read, understand, and comply with this policy. 
 

3. LEGAL AND INTERNATIONAL FRAMEWORK

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ED4S is committed to minimizing its environmental impact and embedding climate responsibility across its operations.

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This policy is guided by the following frameworks:

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Canadian Legislation
 

• Criminal Code of Canada (bribery, fraud, corruption, secret commissions) 

• Corruption of Foreign Public Officials Act (CFPOA), which prohibits bribery of foreign officials 

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International Standards
 

• OECD Convention on Combating Bribery of Foreign Public Officials 

• OECD Guidelines for Multinational Enterprises 

• United Nations Convention against Corruption (UNCAC)

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While ED4S is a small enterprise, we recognize our responsibility to uphold these standards in all business activities. 

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4. DEFINITIONS

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Bribery​

Offering, giving, receiving, or soliciting anything of value to improperly influence a business decision. ​

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Corruption

Abuse of entrusted power for private gain, including fraud, embezzlement, kickbacks, conflicts of interest, and misuse of company resources. 

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Facilitation Payments 

Small, unofficial payments to speed up routine government actions. ED4S strictly prohibits these. 

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Public Official 

Any employee or representative of local, provincial, or federal governments, state-owned enterprises, or international public organizations. 

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5. PROHIBITED PRACTICES
 

ED4S strictly prohibits the following activities: 

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5.1 Bribery & Improper Advantages 
 

No employee or third party may: 
 

• Offer or accept cash, gifts, favors, or incentives 

• Provide anything of value to obtain or retain business 

• Make payments to influence a decision or secure preferential treatment 
   

5.2 Facilitation Payments 
 

All facilitation payments are strictly prohibited, regardless of amount or local customs.
 

5.3 Kickbacks & Secret Commissions 
 

Receiving or offering a portion of a contract payment in return for business advantage is prohibited. 
 

5.4 Conflicts of Interest 
 

Employees must disclose: 
 

• Personal or financial relationships that may influence business decisions 

• Outside employment or consulting engagements 

• Any situation where objectivity could be compromised 
   

5.5 Improper Use of Company Funds 
 

All expenses, invoices, and financial transactions must be accurate, legitimate, and documented. 
 

5.6 Political and Charitable Contributions 
 

Employees may not make donations on behalf of ED4S without written approval from the CEO. 
 

6. GIFTS, HOSPITALITY, AND BUSINESS COURTESY 
 

ED4S recognizes that symbolic relationship-building gestures can be part of business culture. However: 
 

Allowed (with conditions): 
 

• Low-value promotional items (e.g., branded notebooks, pens) 

• Modest hospitality directly related to business activities 

• Small gifts under 100 CAD that are infrequent and not during contract negotiations
   

Not Allowed: 
 

• Cash or cash equivalents 

• Gifts during procurement or tendering 

• Lavish meals, entertainment, or travel 

• Personal favors or services 
   

If unsure, employees must seek approval from the CEO before offering or accepting any gift. 
 

7. WORKING WITH THIRD PARTIES
 

As a training and advisory company, ED4S occasionally engages suppliers, facilitators, or contractors. Third-party risks are proportionally managed by: 
 

• Ensuring service providers certify their compliance with anti-corruption laws 

• Including anti-corruption clauses in contracts 

• Conducting basic due diligence where relevant (professional reputation, conflicts of interest, sanctions checks if applicable) 
   

We will disengage from any third party that fails to meet our ethical standards. 

 

8. BOOKS, RECORDS, AND FINANCIAL CONTROLS 
 

ED4S maintains accurate financial records to demonstrate the legitimacy of all transactions. 

Employees must: 
 

• Submit truthful expense reports 

• Record all payments accurately 

• Avoid creating false or misleading documents 
   

Financial transparency is essential to demonstrating compliance. 
 

9. REPORTING CONCERNS AND WHISTLEBLOWING 
 

ED4S encourages the reporting of any suspected misconduct. Employees and external partners may raise concerns regarding: 
 

• Bribery or attempted bribery 

• Fraud or financial misconduct 

• Conflicts of interest 

• Unethical behavior by contractors or partners
   

Reports can be made directly to: 
Maria Maisuradze, President & CEO 
Email: maria@ed4s.org 
Phone: 1-514-623-6279 
 

No Retaliation 

ED4S prohibits retaliation against anyone who reports a concern in good faith. 

 

10. RESPONSIBILITIES 
 

All Employees and Contractors 
 

• Read and comply with this policy 

• Participate in brief annual reviews/training 

• Report concerns or violations immediately 
   

CEO 
 

• Oversees implementation and enforcement 

• Approves any exceptions (gifts, donations, partnerships) 

• Ensures policy updates in line with legal requirements 
   

Suppliers and Partners 
 

• Must comply with this policy 

• Must ensure their subcontractors follow equivalent standards 

 

11. TRAINING AND AWARENESS
 

Given ED4S’s size, anti-corruption training will be integrated into onboarding and reviewed annually. 

The CEO ensures that employees and contractors understand their obligations. 

 

12. POLICY REVIEW 
 

This policy will be reviewed every two years, or sooner if significant legal or operational changes occur.