1. POLICY

GlueData is committed to conducting business in an ethical and honest manner and is committed to ensuring that bribery and corruption are prevented. The same goes for receiving gifts and/or entrainment with such intent. It is also unethical, and contrary to good corporate governance for businesses.

1.1 Purpose

The purpose of this document is to communicate the principles and guidelines as to what would constitute normal and acceptable behaviour in relation to gifts and entertainment, and as to what would be regarded as unethical, criminal or contrary to good corporate governance and behaviour.

1.2 Scope

This policy applies to all Team Members (whether temporary, fixed term, or permanent), consultants, contractors, or any other person or persons associated with us (including third parties). It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies.

1.3 Definitions:

• Corruption is defined broadly as ‘the abuse of power for personal gain’ and bribery and fraud are considered to be aspects of corrupt practices.
• Bribery is where a person offers, promises, gives or receives, demands or accepts a financial or other advantage to /from another person with the intention to bring about the improper performance by that other person of a relevant function or activity or to reward such improper performance. It also includes situations where the offer or acceptance of the advantage is in itself improper.

1.4 Consequences of non-compliance

Unacceptable behaviour in respect to gifts and entertainment is considered a serious offence and will lead to disciplinary action.

2. GUIDELINES

• GlueData has zero tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships and will uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.
• Consideration must be applied when offering or receiving a gift, invitation or other hospitality. Such expenditures or benefits need to be managed and must always be proportionate to the business circumstances to which the expenditure or benefit relates. Should Team Members be unsure at any time, this must be referred to a Director at GlueData.
• Any gift should be declared to allow for transparency and where relevant, put into an Employer pool for a raffle or given to a chosen charity at Managements’ discretion.
• If any person becomes aware of a circumstance or action that violates or appears to violate this policy on bribery and corruption, they are encouraged to contact a Director at GlueData.

2.1 Determining the intention and appropriateness of gifts/entertainment

• Gifts/services/entertainment offered/received with a view to establishing and strengthening relationships are acceptable, but when these gifts/services/entertainment are offered in order to induce some benefit or result, it becomes a criminal offence.
• The value of gifts/services offered/received should be reasonable to the specific occasion and not be disproportioned to the relationship building it intends to support.
• The person/Employer to whom the gift/entertainment is offered/from whom it is received should be relevant to the building of the relevant relationship.