Anti-Corruption and Bribery Policy

  1. Policy statement
    1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.
    2. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
    3. Neither us, nor our officers or employees:
      1. have been convicted of any offence involving bribery or corruption;
      2. to the best of our knowledge, have been or are the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence of the same; or
      3. have been or are listed by any government agency as being debarred, suspended, proposed for suspension or debarment, or otherwise ineligible for participation in government procurement programmes or other government contracts.
    4. Our employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners and other third parties that we engage with, must comply with our policy on anti-corruption and bribery.
  1. About this policy
    1. It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine. If we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.
    2. In this policy, third party means any individual or organisation and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
  2. Who is responsible for the policy?
    1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
    2. The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
  3. What are bribery and corruption?
    1. Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
    2. An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
    3. A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
    4. Corruption is the abuse of entrusted power or position for private gain.
  4. Third party responsibilities
    1. We require all third parties that we engage with to adhere to the following:
      1. compliance with all applicable laws, regulations, and codes relating to anti-bribery and anti-corruption including but not limited to the Bribery Act 2010;
      2. not engage in any activity, practice or conduct which would constitute an offence under sections 1, 2 or 6 of the Bribery Act 2010 if such activity, practice or conduct had been carried out in the UK;
      3. have and maintain in place its own policies and procedures, including adequate procedures under the Bribery Act 2010, to ensure compliance and to enforce them where appropriate;
      4. promptly report to us any request or demand for any undue financial or other advantage of any kind received by them in connection with the performance under any agreement with us;
      5. immediately notify us (in writing) if a foreign public official becomes an officer or employee of them or acquires a direct or indirect interest in them;
      6. warrant that it has no foreign public officials as officers or employees or direct or indirect owners at the date of any agreement with us;
      7. as such intervals as we deem necessary, certify to us that they have complied with this Policy.
    2. We require that all third parties we engage with to ensure that any person associated with them who is performing services in connection with any agreement with us does so only on the basis of a written contract which imposes on and secures from such person terms equivalent to this policy. They shall in all circumstances be responsible for the observance and performance by such persons, and shall in all circumstances be directly liable to us for any breach by such persons, howsoever arising.
  1. Facilitation payments and kickbacks
    1. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
    2. Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some other jurisdictions.
    3. Kickbacks are typically payments made in return for a business favour or advantage.
  2. Gifts, hospitality and expenses
    1. We allow reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
      1. establishing or maintaining good business relationships;
      2. improving or maintaining our image or reputation; or
      3. marketing or presenting our products and/or services effectively.
    2. Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable.
    3. Reimbursing a third party’s expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
    4. We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. We will always consider the intention behind it.
  3. Donations
    1. We do not make contributions to political parties.
    2. We only make charitable donations that are legal and ethical under local laws and practices.
  4. Record-keeping
    1. We keep financial records and have appropriate internal controls in place which evidence the business reason for making payments to third parties and the steps taken to ensure compliance with our obligations.
  5. responsibilities
    1. Individuals under our control and third parties we engage with must ensure that they have read, understand and comply with this policy.
    2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. Individuals under our control and third parties we engage with are required to avoid any activity that might lead to, or suggest, a breach of this policy.
    3. Individuals under our control and third parties we engage with must notify our compliance manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
  6. Raising a concern
    1. Individuals are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
    2. If individuals under our control or third parties we engage with are offered a bribe, or are asked to make one, or if they believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, they must report it to their manager or the compliance manager as soon as possible.
  7. Protection
    1. Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
    2. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.
  8. Training and communication
    1. Training forms part of the induction process for all individuals who work for us, and regular training is provided as necessary.
  1. Statement of Ethics
    1. We pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organisation.
    2. We condemn corruption in all its forms and we will not tolerate it in our business or in those we do business with. From the confines of our working environments, it is sometimes difficult to grasp the scale of the damage that bribery does to societies. It is not a victimless crime.
    3. If any of our employees or third parties that we are engaged with are convicted of a bribery offence, Bond Digital Health Ltd may be significantly fined and suffer lasting reputational damage. If an individual is convicted of a bribery offence, they could face up to ten years in prison. The potential harm done by bribery, both to us and to you, is long term and hugely outweighs any potential short term gain.
    4. We are committed to eradicating corruption and we will stand by individuals in acting ethically.

David Taylor, COO, Bond Digital Health Ltd