We take a zero-tolerance approach to bribery and corruption and pledge to be transparent, professional, and fair in our day-to-day operations. We comply with all prominent Anti-Bribery laws around the world such as the Bribery Act 2010 (UK) and the U.S. Foreign Corrupt Practices Act (1977).
For the sake of clarity, the terms ‘bribery’ and ‘corruption’ shall be defined as follows:
Bribery is offering, promising, giving or accepting any financial or other advantages, to make someone act improperly, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
Corruption is the abuse of entrusted power or position for private gain.
This policy does not prohibit the giving or accepting of reasonable and appropriate gifts or hospitality for a reasonable and genuine purpose such as building relationships, marketing, and reputation management. Examples of what is excluded from this policy are:
- sending merchandise to a customer,
- meeting a candidate in the recruitment pipeline before an offer is made,
- having a customer or potential customer send a voucher or discount code for a team member or the whole team etc.
A gift is inappropriate if it is unreasonably lavish or extravagant. Such gifts should not be accepted.
All expense claims relating to hospitality, gifts, or payments to third parties must be submitted as expenses.
You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage to your Lead or the VP of Operations.
If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your Lead or the Compliance Team.