Anti-Corruption and Bribery Policy
ANTI-CORRUPTION AND BRIBERY POLICY
1. POLICY STATEMENT
Asset Reality is committed to acting honestly, fairly, ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems to counter bribery and corruption. Asset Reality will ensure that its business dealings and relationships are conducted in compliance with all UK and US laws relating to the prevention of bribery and corruption, including the Bribery Act 2010 and the US Foreign Corrupt Practices Act (the Acts)
2. THE PURPOSE AND SCOPE OF THIS POLICY
2.1. This policy applies to all persons working for us or any of our subsidiary companies, or on our/their behalf, in any capacity, including employees at all levels and grades (whether permanent, fixed-term or temporary), directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners, sponsors, or any other person associated with us, wherever located (“Asset Reality Staff”).
2.2. In this policy, the term “third party” means you, the Client, and includes your business contacts, agents, advisers, and any government and public bodies, including their advisors, representatives and officials, politicians, and political parties to whom you may direct or indirectly connect with in connection with this Agreement or the Services thereof.
3. WHAT CONSTITUTES BRIBERY AND CORRUPTION
3.1. A bribe is an inducement or reward offered, promised, or provided to improperly gain any commercial, contractual, regulatory, or personal advantage, which may constitute an offence under the Act, namely:
3.1.1. giving or offering a bribe;
3.1.2.receiving or requesting a bribe; or
3.1.3.bribing a foreign public official.
3.2. Asset Reality prohibits all forms of bribery, whether directly by Asset Reality Staff or a Third Party. Asset Reality Staff are prohibited from soliciting, arranging, or accepting bribes intended for commercial, contractual, regulatory, employee’s benefit or that of the employee’s family, friends, associates, or acquaintances.
4. FACILITATION PAYMENTS AND KICKBACKS
4.1. Asset Reality does not accept and will not make any form of facilitation payments of any nature. Asset Reality recognises that facilitation payments are small unofficial payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement and that facilitation payments remain illegal under the Acts.
4.2. Asset Reality does not allow kickbacks to be made or accepted and recognizes that kickbacks are typically made in exchange for a business favour or advantage.
5. POLITICAL CONTRIBUTIONS
5.1. A political contribution is defined as a contribution, financial or in-kind, to support a political cause.
5.2. Asset Reality and its employees or agents are forbidden to make direct or indirect contributions, whether in cash, kind, or by any other means, to political parties, organisations or individuals engaged in politics, as a way of obtaining an advantage in business transactions.
6. GIFTS AND HOSPITALITY
6.1. Asset Reality does not prohibit normal and appropriate gifts and hospitality (given and received) to or from a Third Party unless otherwise explicitly stated. However, specific internal policies and procedures are in place as to what is to be regarded as normal and appropriate, subject to the principles set out below:
● must not be made to improperly influence a Third Party or Asset Reality Staff to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
● must comply with local law in all relevant countries;
● must be given in the name of the organisation, not in an individual’s name;
● must not include cash or a cash equivalent;
● must be appropriate in the circumstances;
● must be of an appropriate type and value and given at an appropriate time considering the reason for the gift;
● must be given openly, not secretly; and
● in the case of gifts, they must not be offered to or accepted from, government officials or representatives, politicians, or political parties, without prior approval from the Board of Directors of Asset Reality.
6.2. Asset Reality recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. However, our policy is to decline all gifts or requests for gifs where they contravene the principles stated above.
7. REPORTING AND PROTECTION
7.1. We, Asset Reality, enforce this Policy through our internal processes. As part of that enforcement, we ask all Clients to raise concerns about any issue or suspicion of the occurrence of any of the prohibited activities as described (“Prohibited Activities”) at the earliest possible stage.
You may raise concerns directly to: legal@assetreality.com
8. CLIENT/THIRD-PARTY COMPLIANCE
In signing any agreement and/ or procuring services from Asset Reality, you agree to your designation as ‘third party’. You further agree that you will not receive or request the Prohibited Activities directly or indirectly or any by other as stated within the third-party definition.
Last Updated: 25 November, 2024
Version: 1.0
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