Anti-bribery policy

Purpose and applicability

We are committed to conducting our business ethically and with integrity. We take reasonable and appropriate measures to ensure that our firm does not participate in any corrupt activities.
This policy is meant to communicate  our company's commitment in preventing and curbing bribery and corruption. This policy sets out the responsibility of those that work with us or for us or on behalf of us, whether under contractual arrangement or not (collectively referred to "associated person"), with regards to observing our firm's commitment.
All associated persons are expected to read and understand this policy. Violation of any provision stated in this policy may result in disciplinary action, including termination of any contractual arrangement.  
This policy is not meant to be exhaustive and there may be additional obligations that are required to be met in working for, with or on our firm's behalf. For all intent and purposes, all associated persons shall always observe and ensure compliance with all applicable laws in the performance of their duties. 

​Compliance with the law

Our company are bound by and will comply with all laws in countries that we operate from. 
For the purpose of this policy, we adopt Transparency International's definition of bribery which means; the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. Inducements can take the form of money, gifts, loans, fees, rewards or other advantages (taxes, services, donations, favours etc.).

Basic principle

All associated persons shall not bribe or must not use any intermediary to commit acts of bribery.  Associated persons must refrain from offering, promising, giving, receiving or soliciting anything of value that may be perceived as a bribe and be viewed as an attempt to illicitly influence the decision or action of a person in a position of trust for the intended benefit of our company. 

Responsibilities

The Directors of our company is ultimately responsible to ensure that this policy complies with our company's legal and ethical obligations and that all associated persons that are under our control complies with it. 
We recognises the importance of raising concerns on any suspected or actual bribery offences and encourages associated persons to come forth to raise such a report through our company's whistleblowing platform. 
Concerns can be raised through this link (https://suara.live/concern/index/30)
No persons associated with our company shall suffer any detrimental treatment for refusing to take part in bribery or corruption, or for reporting any concerns in good faith on actual or suspected bribery offence that has taken place or will take place, even if such action may be disadvantageous to our company (e.g. loss of business). Any person that retaliates against a person that raised a concern in good faith shall be subject to disciplinary actions, including dismissal and termination. 

Record keeping

We shall prepare and maintain our books and records accurately and will have appropriate internal controls in place to evidence all payments made, whether in-kind or not.