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Anti-Bribery Policy
Introduction
This Anti-Bribery Policy establishes our firm commitment to maintaining the highest ethical standards in all aspects of our business activities. We categorically oppose bribery and corruption in any form and recognise that such conduct undermines the integrity of our company, our staff, our partners, and the communities in which we operate. The purpose of this policy is to provide a clear framework for our employees, directors, contractors, and suppliers to understand their obligations concerning anti-bribery laws and the expectations for maintaining the integrity of our business relationships.
Commitment to Ethical Conduct
We are committed to conducting our business in a transparent, honest, and ethical manner at all times. The company is resolute in its stance that bribery and corruption will not be tolerated, regardless of whether such actions occur in public or private sectors, or whether they are deemed to be acceptable in certain countries or cultures. We believe that trust and integrity are the foundations of our long-term success and that engaging in bribery or any related unethical practices will irreparably damage the company’s reputation and relationships with stakeholders.
Prohibition of Bribery
Bribery is defined as offering, giving, receiving, or soliciting something of value to influence the actions of an individual in a position of trust. This includes both direct and indirect bribery, as well as attempts to use bribes in any business transactions, both internal and external. It is strictly prohibited to offer or receive gifts, payments, or favours that might influence or be perceived to influence business decisions in an unethical or improper manner.
This prohibition extends to all employees, directors, contractors, agents, suppliers, and any third parties acting on behalf of the company. We recognise that bribery may take various forms, including but not limited to cash payments, extravagant gifts, entertainment, donations, or favours, and this policy applies to all such actions. Even if no tangible benefit is received by the individual, it is still considered bribery if the action compromises or appears to compromise the individual’s objectivity, impartiality, or integrity.
Corporate Social Responsibility and Due Diligence
We take our social responsibility seriously and ensure that we comply with all relevant anti-bribery and anti-corruption laws and regulations, both in the jurisdictions where we operate and those under international frameworks. Due diligence will be conducted when entering into relationships with third parties, including business partners, suppliers, and agents, to ensure they uphold the same high standards with regard to ethical conduct. We expect the same level of commitment to anti-bribery principles from all individuals and entities associated with the company.
Before establishing a relationship with a third party, the company will carry out a rigorous evaluation to determine the integrity and business practices of the other party. This includes examining the third party’s financial position, reputation, and any previous legal violations related to bribery or corruption. Any concerns raised during the due diligence process will be addressed, and in cases where the third party does not meet our ethical standards, we will terminate or refrain from establishing the business relationship.
Gifts and Hospitality
We recognise that offering or receiving modest gifts or hospitality is a common practice in business relationships. However, it is essential that gifts and hospitality are offered and accepted in a manner that is not intended to influence business decisions or create an obligation. All gifts, meals, entertainment, and other forms of hospitality must be reasonable, proportionate, and consistent with our values of transparency and integrity.
Employees and representatives of the company are expected to avoid any situations where gifts or hospitality may be perceived as a bribe or an attempt to improperly influence decisions. In cases where a gift or hospitality is offered, the value, intent, and context should be assessed to determine whether it is appropriate and in line with the company’s anti-bribery principles. Any gift, hospitality, or invitation that could raise doubts about the intention behind it must be reported to a senior manager or the compliance officer.
Reporting and Accountability
We encourage an open and transparent environment where any concerns regarding bribery or unethical behaviour can be raised without fear of retaliation. If any employee, contractor, supplier, or third-party partner believes that bribery or corrupt practices are taking place, they are required to report these concerns immediately. This can be done through established reporting channels, such as direct communication with a supervisor, a designated compliance officer, or an anonymous whistleblowing system, if available.
All reports of suspected bribery or corruption will be treated seriously and investigated promptly. The company commits to maintaining confidentiality and ensuring that those who raise concerns in good faith are protected from any form of retaliation or adverse consequences. Any individual found to be involved in bribery or corruption will face disciplinary action, which may include dismissal, legal action, or reporting to relevant authorities.
Training and Awareness
We are committed to providing ongoing training to all employees to ensure they understand the implications of bribery and corruption and how to recognise and avoid such behaviours. The company will also provide regular updates and refresher courses to keep employees informed of any changes to anti-bribery laws, industry standards, or company practices.
This training will cover areas such as recognising signs of bribery, understanding the legal framework surrounding anti-bribery and corruption, the appropriate conduct for gifts and hospitality, and the procedures for reporting unethical activities. The training will be mandatory for all employees, particularly those in positions of seniority or responsibility, as they may be more susceptible to facing situations where bribery or corruption could be present.
Enforcement of the Policy
This policy applies to all levels of the company, including directors, employees, contractors, suppliers, and any third parties who conduct business on behalf of the company. Compliance with this policy is not optional, and failure to adhere to the principles set forth herein may result in disciplinary action, up to and including termination of employment or business relationships.
The company will take all necessary steps to ensure that the policy is enforced, and any violations will be addressed with the appropriate level of seriousness. We will continue to monitor, review, and improve our internal controls and processes to prevent bribery and corruption within the organisation, and we will remain vigilant in our commitment to maintaining an ethical and transparent working environment.
Conclusion
This Anti-Bribery Policy reflects our strong commitment to ethical business practices and our zero-tolerance stance on bribery and corruption. We are dedicated to upholding the highest standards of integrity in all our business operations and expect all individuals associated with the company to adhere to these principles. By doing so, we aim to protect the long-term reputation of our business and ensure that we continue to build trustworthy relationships with all our stakeholders.