Anti-Corruption Policy
1. Introduction
Alloc8tor Ltd (hereinafter referred to as "the Company") is committed to maintaining the highest standards of integrity, ethics, and transparency in all aspects of its business operations. This Anti-Corruption Policy outlines the Company's commitment to preventing and combating corruption in all its forms and provides guidelines for all employees, contractors, consultants, agents, and business partners to follow.
2. Scope
This policy applies to all individuals associated with the Company, including but not limited to employees, directors, officers, contractors, consultants, agents, suppliers, distributors, vendors, and any other third parties acting on behalf of the Company.
3. Compliance with Applicable Laws
The Company and its employees must comply with all applicable laws, regulations, and international conventions relating to anti-corruption and bribery. This includes but is not limited to the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act, and any other relevant anti-corruption laws of the countries where the Company operates.
4. Prohibited Conduct
The Company strictly prohibits any form of corruption, bribery, facilitation payments, or any other illegal or unethical conduct. The following activities are strictly prohibited:
a. Offering, promising, giving, or accepting bribes, kickbacks, or other improper advantages, whether directly or indirectly, to improperly influence a person's actions or decisions.
b. Facilitating or tolerating corrupt practices, including providing or receiving gifts, entertainment, or hospitality that may improperly influence a person's actions or decisions.
c. Engaging in extortion, embezzlement, fraud, money laundering, or any other illegal or unethical activity.
5. Conflicts of Interest
All individuals associated with the Company must avoid any conflicts of interest that could compromise their judgment, objectivity, or integrity. This includes avoiding situations where personal interests conflict with the Company's interests or where personal relationships could influence business decisions.
6. Gifts, Entertainment, and Hospitality
The Company recognizes that giving and receiving reasonable and proportionate gifts, entertainment, and hospitality can be part of normal business relationships. However, such activities must not be used as a means to improperly influence business decisions. All individuals associated with the Company must adhere to the following guidelines:
a. Gifts, entertainment, and hospitality should be modest, appropriate, and in line with accepted business practices.
b. Gifts, entertainment, and hospitality must not be offered or accepted with the intent to influence business decisions or gain unfair advantage.
c. Approval from a designated authority within the Company must be obtained for gifts, entertainment, or hospitality that exceed reasonable limits or may give rise to a perception of impropriety.
7. Due Diligence on Business Partners
The Company is committed to working with reputable business partners who uphold high ethical standards. Before entering into a business relationship with any third party, the Company shall conduct due diligence to assess the potential risks associated with corruption and bribery. This includes but is not limited to conducting background checks, assessing the reputation and integrity of the business partner, and including appropriate anti-corruption provisions in contracts.
8. Reporting and Whistleblowing
The Company encourages the reporting of any concerns or suspicions regarding potential corrupt activities. All individuals associated with the Company have a responsibility to promptly report any actual or suspected violations of this policy. Reports can be made to the employee's supervisor, the HR department, or through an anonymous reporting mechanism established by the Company.
9. Non-Retaliation
The Company prohibits any form of retaliation against individuals who report concerns or suspicions of corruption in good faith. Any individual found to engage in retaliation will be subject to disciplinary action, up to and including termination of employment or contract.
10. Training and Communication
The Company shall provide appropriate training to employees and other relevant parties to raise awareness
about anti-corruption laws, policies, and procedures. Regular communication and reminders will be disseminated to ensure all individuals associated with the Company understand their obligations and responsibilities.
11. Monitoring and Compliance
The Company will periodically review and monitor the effectiveness of this policy and related procedures. Internal controls and audits may be conducted to ensure compliance with the policy and to identify any potential areas of risk.
12. Disciplinary Actions
Any individual found to have violated this policy will be subject to disciplinary action, which may include but is not limited to warnings, retraining, suspension, termination of employment, or legal action, depending on the severity and nature of the violation.
13. Policy Review
This policy will be reviewed periodically to ensure its continued relevance and effectiveness. Any updates or amendments to the policy will be communicated to all relevant individuals.
By adhering to this Anti-Corruption Policy, Alloc8tor Ltd aims to maintain its reputation as a trustworthy and ethical company, committed to conducting business with integrity and fairness.
This policy was last updated on April 23rd, 2025