Anti-Bribery Policy

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Tasrie IT Services is committed to conducting business ethically and with integrity. This Anti-Bribery Policy sets out our stance against bribery and corruption in all our business activities.

Policy Statement

We have a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate. We will uphold all laws relevant to countering bribery and corruption.

Scope

This policy applies to:

  • All employees, officers, and directors of Tasrie IT Services
  • Contractors, consultants, and temporary workers
  • Agents and representatives acting on our behalf
  • Business partners, suppliers, and third parties working with us

What is Bribery?

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. This includes:

  • Offering a bribe: Promising, offering, or giving a financial or other advantage
  • Receiving a bribe: Agreeing to receive or accepting a financial or other advantage
  • Bribing a foreign public official: Offering, promising, or giving a bribe to influence a foreign public official
  • Facilitation payments: Unofficial payments made to secure or expedite routine governmental actions

Prohibited Activities

The following activities are strictly prohibited:

  • Giving, offering, or promising bribes to anyone
  • Receiving, agreeing to receive, or soliciting bribes
  • Making facilitation payments
  • Giving or receiving kickbacks
  • Using intermediaries to engage in bribery
  • Making political contributions on behalf of the company without authorization
  • Making charitable donations intended to influence business decisions

Gifts and Hospitality

We recognize that business gifts and hospitality can build legitimate business relationships. However, they must not:

  • Be given with the intention of influencing business decisions
  • Be lavish or extravagant
  • Create a sense of obligation
  • Violate local laws or regulations
  • Be given or received in cash or cash equivalents

Acceptable Gifts and Hospitality

Gifts and hospitality are acceptable if they:

  • Are of nominal value and infrequent
  • Are openly given and properly documented
  • Are appropriate in the circumstances
  • Are given in the company's name, not personally
  • Would not embarrass the company if publicly disclosed

Prior Approval

Gifts or hospitality exceeding a reasonable threshold must be approved by management and documented appropriately.

Due Diligence on Third Parties

We conduct appropriate due diligence on:

  • New business partners and suppliers
  • Agents and intermediaries
  • Consultants and advisors
  • Joint venture partners

We require contractual terms that:

  • Prohibit bribery and corruption
  • Require compliance with anti-bribery laws
  • Allow for termination if bribery is suspected
  • Include audit rights

Record Keeping

We maintain accurate and complete records of:

  • All financial transactions
  • Gifts and hospitality given or received
  • Expenses and reimbursements
  • Contracts with third parties

All records must be:

  • Accurate and complete
  • Maintained in accordance with retention policies
  • Available for internal and external audit

Training and Awareness

We provide regular training to ensure all personnel:

  • Understand this policy and their obligations
  • Can identify potential bribery situations
  • Know how to report concerns
  • Understand the consequences of non-compliance

Reporting Concerns

We encourage reporting of any concerns about potential bribery or corruption. You can report concerns:

  • To your direct manager or leadership
  • Through our confidential reporting channels
  • Via email to: [email protected]

All reports will be:

  • Treated seriously and investigated promptly
  • Handled confidentially to the extent possible
  • Protected against retaliation

Protection from Retaliation

No one will suffer adverse consequences for refusing to participate in bribery or for raising genuine concerns about potential bribery, even if this results in lost business opportunities.

Consequences of Non-Compliance

Violations of this policy may result in:

  • Disciplinary action, up to and including termination of employment
  • Termination of business relationships
  • Legal action and prosecution
  • Significant fines and penalties for individuals and the company
  • Reputational damage

Responsibilities

Management

Management is responsible for:

  • Ensuring awareness and understanding of this policy
  • Setting a good example through ethical behavior
  • Creating an environment where concerns can be raised
  • Taking appropriate action on reported concerns

All Personnel

All personnel must:

  • Comply with this policy
  • Complete required training
  • Report suspected violations
  • Cooperate with investigations

Monitoring and Review

We monitor compliance through:

  • Regular internal audits
  • Review of expense reports and financial records
  • Investigation of reported concerns
  • Annual policy review and updates

Contact

For questions about this policy or to report concerns:

Email: [email protected]
Phone: +44 204 587 6321
Address: Tasrie IT Services, Inc., 71-75 Shelton St, London WC2H 9JQ, United Kingdom