Summary
AT Worthy Technology Inc. and its affiliates, where applicable, referred to in this policy as the "Company," are committed to conducting business with integrity, transparency, and accountability. The Company does not tolerate bribery, corruption, or any improper conduct that could compromise its reputation, independence, or the trust placed in it by clients, partners, public authorities, or other stakeholders.
This Anti-Bribery and Anti-Corruption Policy, referred to as the "Policy," prohibits all forms of bribery and corrupt conduct, whether involving public officials or private individuals. This includes offering, promising, authorizing, giving, requesting, or accepting anything of value, directly or indirectly, in order to obtain an improper advantage, influence a decision, secure business, retain business, or reward improper conduct.
Violations of this Policy may result in disciplinary action, up to and including termination of employment or engagement, and may also expose individuals and the Company to civil or criminal liability.
Purpose of the Policy
The purpose of this Policy is to set out the Company's approach to preventing bribery and corruption, clarify the responsibilities of employees and associated persons, and support compliance with applicable anti-corruption laws and regulations in all jurisdictions where the Company operates or does business.
The Company expects all personnel to uphold high ethical standards and to act with care, judgment, and integrity in all business dealings. The Company may also provide training, guidance, and internal controls to help identify, prevent, and address bribery and corruption risks.
What Is Bribery?
Bribery is the offering, promising, giving, requesting, agreeing to receive, or accepting of any financial or other advantage in order to improperly influence a person's actions, decisions, or judgment, or to reward them for doing so.
A bribe can take many forms. It is not limited to cash payments. It may include gifts, hospitality, travel, favors, services, job opportunities, charitable contributions, sponsorships, discounts, confidential information, or anything else of value, whether tangible or intangible.
Bribery can occur in dealings with government officials, clients, vendors, consultants, contractors, experts, intermediaries, or any other third party. An attempt to bribe, even if unsuccessful, may still constitute a violation of this Policy and applicable law.
Scope
This Policy applies to all directors, officers, employees, contractors, consultants, temporary staff, and any other individuals acting for or on behalf of the Company, wherever located.
The Company also expects third parties acting on its behalf to maintain standards consistent with this Policy. Where appropriate, the Company may assess corruption-related risks in connection with third-party relationships.
Zero-Tolerance Approach
The Company takes a zero-tolerance approach to bribery and corruption. No employee or representative of the Company may offer, give, solicit, or accept any improper payment, gift, benefit, or advantage in connection with the Company's business.
This prohibition applies regardless of local custom, perceived business practice, competitive pressure, or the value involved.
The Company also prohibits:
- facilitation payments, meaning unofficial payments made to secure or expedite routine governmental actions
- kickbacks, including the return of part of a contract payment in exchange for business or favorable treatment
- improper use of third parties to do something that would be prohibited if done directly by the Company or its personnel
Gifts, Hospitality, and Legitimate Business Courtesies
The Company recognizes that modest gifts, hospitality, and business courtesies may be appropriate in certain professional settings. However, these must never be offered or accepted where they are intended, or could reasonably appear intended, to influence a business decision or secure an improper advantage.
Any gift, meal, entertainment, travel, or hospitality must be:
- reasonable in value and frequency
- given openly and transparently
- lawful under applicable rules and regulations
- connected to a legitimate business purpose
- not intended to influence, reward, or induce improper conduct
Cash or cash equivalents, including gift cards or vouchers, should not be given or accepted unless expressly authorized under Company procedures.
Additional caution must be exercised when dealing with public officials, since stricter legal standards often apply.
Responsibilities of Personnel
All personnel covered by this Policy are expected to:
- read, understand, and comply with this Policy
- avoid any conduct that could create even the appearance of bribery or corruption
- exercise sound judgment when offering or accepting gifts, hospitality, or other benefits
- maintain accurate and complete records of relevant transactions and expenses
- raise concerns promptly if they become aware of or suspect misconduct
Managers are expected to promote compliance within their teams and ensure that business activities under their supervision are carried out in accordance with this Policy.
Books, Records, and Internal Controls
The Company requires accurate and complete books, records, and accounts. No false, misleading, incomplete, or artificial entries may be made in the Company's records for any reason.
All payments, expenses, reimbursements, gifts, entertainment, donations, sponsorships, and other transfers of value must be properly documented and supported by a legitimate business purpose.
Off-book accounts, concealed transactions, and undocumented payments are prohibited.
Reporting Concerns and Whistleblowing
Any employee or representative who knows of, suspects, or is asked to participate in conduct that may violate this Policy must report the matter promptly to management or the appropriate internal contact.
Reports may concern actual misconduct, suspected misconduct, attempted misconduct, or pressure to engage in questionable behavior.
The Company will review reported concerns seriously and, where appropriate, investigate them in a fair and timely manner. Retaliation against any person who raises a concern in good faith, or who assists in an investigation, is prohibited.
Where permitted by law and practical under the circumstances, the Company will seek to protect the confidentiality of individuals who report concerns.
Consequences of Violations
Violations of anti-bribery and anti-corruption laws can result in severe consequences for both individuals and the Company, including fines, civil penalties, criminal sanctions, reputational harm, loss of business opportunities, and regulatory action.
Any violation of this Policy may lead to disciplinary measures, up to and including termination of employment, contract, or other relationship with the Company.
Training and Awareness
The Company may provide anti-bribery and anti-corruption training to employees and relevant personnel as appropriate to their roles and responsibilities. Training may cover legal obligations, practical risk scenarios, reporting expectations, and the Company's standards for ethical conduct.
The Company may also update this Policy and related procedures from time to time to reflect changes in legal requirements, business operations, or risk exposure.
Questions
Questions regarding this Policy or its application should be directed to:
info [at] atworthy [dot] com