Anti-Bribery and Corruption Policy​

DolpTec (the "Company") is a highly respectable and recognizable organisation. It has gained its name and reputation among its competitors and consumers through its commitment to conducting business according to moral, ethical, and legal standards. The Company does not allow and tolerate any kind of bribery and corruption.

This Anti-Bribery and Corruption Policy (the “Policy”) discourages and prohibits any kind of bribe or corrupt practice with any kind of stakeholder, including offering, promising, or providing any kind of means or value to any stakeholder, including customer, government official, business partner, or a third party to induce any improper action in relation to our business.

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Objective​

 

This Policy outlines the Company's moral and legal responsibility to counter bribery and corruption and provide tools and methods to keep check and balance on such practices.

 

DEFINITION

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Bribery is, in the conduct of the Company’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance,from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by DolpTec employees or by third parties acting for or on behalf of DolpTec.

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PURPOSE

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The purpose of this policy is to convey to all employees and interested parties of DolpTec the rules of the Company in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that DolpTec conducts its business in a fair, professional and legal manner.

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OFFENCE

 

It is a criminal offence to:

• offer a bribe

• accept a bribe

• bribe a foreign official

• as a commercial organisation, to fail to prevent a bribe

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.

 

DEFINITIONS OF BRIBERY AND CORRUPTION

 

Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business giving or receiving money, gifts, meals, entertainment or anything else of value as an inducement to a person to do something which is dishonest or illegal.

 

Scope

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This Policy applies to all the employees, directors, officers, and any third party which is directly engaged with our business. Further, the Policy applies to any subsidiary, branch office, or liaison office of the Company, regardless of its location.

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Applicable Laws

 

This Policy is governed by the anti-corruption and anti-bribery laws of the United Kingdom, the Anti-Bribery Act 2010.

 

GIFTS AND HOSPITALITY

 

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded.

This does not constitute bribery and consequently such actions are not considered a breach of this policy. Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation. Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present. No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from the reporting manager. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from the reporting manager.

A record will be made of every instance in which gifts or hospitality are given or received.

As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.

 

POLICY

 

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact the Company officer so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to the Company officer. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

 

DolpTec takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self employed, an agency worker, contractor etc.

 

Prohibition of Bribery

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• The company employees are prohibited from offering, promising, or sanctioning any kind of payment to government officials to secure improper business advantage or influence bureaucratic work.

• The Company prohibits employees from taking any ill gain or advantage through improper means from any private entities.

Employees are strictly advised to obtain approval from the Company to advance any item of value to any government official or private entity.

Provision of any kind of travel, gifts, cash, or meals to any government official or any person in exchange for any ill gain is prohibited.

Use of donations for any unfavourable gain or to influence any person is strictly prohibited. The Company will sanction any kind of charitable gesture or donation through the proper procedure.

Sometimes it must be necessary to appropriate funds to promote or demonstrate Company products or services, but it must not be used to influence the normal functioning of such officers. Before appropriating such funds, approval from the concerned department is necessary.

It is strictly prohibited to employ any government official, employee of a private entity, or their relatives to influence or gain an undue benefit. If the employment of such a person is necessary, prior approval of the Company's legal counsel is necessary.

Political contributions advanced to influence government officials are strictly prohibited. All political contributions will go through the proper channel outlined in a separate policy.

Third parties associated with the Company, either directly, are strictly prohibited from making any corrupt practice on behalf of the Company.

All payments to third parties in exchange for their services and contributions to the Company must be recorded appropriately and evidenced. Additionally, third parties interacting with a government official on behalf of the Company must be documented.

All third parties are obligated to do due diligence before engaging with government officials on behalf of the Company.

To ensure compliance with this Policy, the Company may conduct periodic audits of the Company. All employees, directors, officers, and stakeholders are obligated to cooperate with the audit process.

All directors, officers, employees, and stakeholders are obligated to report any violation of this Policy to the Company's legal team. Failure to report such an incident constitutes a violation of this Policy and leads to disciplinary action.

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The Policy brought in effect on 01-12-2023