Anti-Bribery & Anti-Corruption Policy
Anti-Bribery & Anti-Corruption Policy
1. Purpose
Evamp & Saanga is committed to ethical business practices and compliance with anti-corruption and anti-bribery laws including FCPA (USA), UK Bribery Act 2010, and local laws.
2. Introduction
All employees must avoid conflicts of interest and refrain from unethical practices including bribery and facilitation payments. Key commitments include:
- No giving/offering of bribes or inducements.
- No advantages to public officials.
- No third-party bribery.
- Due diligence in business partnerships.
- Financial integrity and transparent records.
- Reporting channels for concerns.
3. Compliance with Standards and Best Practices
3.1 Awareness of Laws
Compliance with local/international regulations including FCPA, UK Bribery Act.
3.2 Client Code of Ethics
Obligation to follow ethics codes under client agreements.
4. Anti-Bribery & Anti-Corruption Policy
4.1 Prohibitions
Strict ban on bribery, facilitation payments, and unethical third-party actions.
4.2 Third-Party Requirements
All contracts must include anti-bribery clauses. Due diligence is mandatory.
5. Compliance & Training
5.1 Oversight
Monitored by senior management and legal teams. Regular audits.
5.2 Employee Training
Annual mandatory anti-bribery training covering FCPA, UK Bribery Act, Code of Ethics.
Whistleblower Policy
5.1 Purpose
Encourages employees to report unethical or illegal conduct. Reports are taken seriously with full protections for whistleblowers.
5.2 Reporting Mechanisms
Reports can be submitted anonymously via:
- Whistleblower Report Officer (WRO)
- HR
- Confidential email or phone
5.3 Identity Protection and Non-Retaliation
- Whistleblowers are protected from retaliation.
- Identities kept confidential unless legally required to disclose.
- Investigations handled by the Whistleblower Investigation Officer (WIO).
5.4 Roles & Responsibilities
| Role | Description | Designated Roles |
|---|---|---|
| WRO | Receives reports | Directors, Team Leads, InfoSec Officer |
| WIO | Investigates reports | HR Officer, Admin Executive, Technical Lead, InfoSec Officer |
| WB Committee | Oversees whistleblower program | HR Manager, Director PM, Technical Lead, InfoSec Manager |
| WB Policy Owner | Policy oversight | COO, CTO, CEO |
5.5 Who is a Whistleblower?
Anyone (current/former employees, contractors, volunteers, family members) who reports misconduct or legal breaches.
6. What is Reportable Conduct?
Any suspected misconduct, improper affairs, or legal contraventions. Excludes personal grievances.
7. Identity Protection
Disclosure identity only shared:
- With consent
- If legally required
- If non-identifying info is used and identity risk minimized
8. Policy Monitoring & Review
- COO responsible for updates.
- Oversight by Board and compliance.
- Reviewed annually or after legal/regulatory changes.
Evamp & Saanga provides its employees and other external stakeholders a dedicated communication channel for compliance concerns.
Email at: compliance@evampsaanga.com
