Anti-Bribery and Corruption Policy

Introduction

At Not Yet Branded, we are committed to conducting our business with the highest ethical standards. This Anti-Bribery and Corruption (ABAC) Policy outlines our zero-tolerance approach to bribery, corruption, and unethical practices. It applies to all employees, contractors, suppliers, and business partners associated with our organization.

Definitions

  1. Bribery:

    • The offering, giving, receiving, or soliciting of anything of value as an inducement or reward for an action that is illegal, unethical, or a breach of trust.
  2. Corruption:

    • Any abuse of entrusted power for personal gain or advantage.

Policy Statement

  1. Zero Tolerance:

    • Not Yet Branded has a zero-tolerance policy regarding bribery and corruption. We will not engage in any form of bribery, kickbacks, or unethical practices.
  2. Compliance with Laws:

    • We comply with all applicable anti-bribery and corruption laws, including the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
    • Our employees and business partners must adhere to these laws.
  3. Prohibited Conduct:

    • Employees and business partners must not:
      • Offer, promise, or give bribes to anyone, including public officials or private individuals.
      • Accept bribes or kickbacks.
      • Facilitate or participate in corrupt practices.
      • Use intermediaries to conceal bribery.
      • Engage in any activity that could be perceived as bribery or corruption.
  4. Gifts, Hospitality, and Donations:

    • Gifts, hospitality, and donations must be transparent, reasonable, and proportionate.
    • Approval processes are in place for such interactions.
  5. Third Parties and Due Diligence:

    • We conduct due diligence on suppliers, agents, and business partners to assess their ABAC practices.
    • Contracts include anti-bribery clauses.
  6. Reporting and Whistleblowing:

    • Employees must report any suspected bribery or corruption promptly.
    • Whistleblowers are protected from retaliation.

Training and Communication

  1. Training:

    • All employees receive ABAC training.
    • Regular refresher training is provided.
  2. Communication:

    • This policy is communicated to all employees, contractors, and business partners.
    • It is available on our website and intranet.

Monitoring and Review

  1. Monitoring:

    • We monitor compliance with this policy through audits and risk assessments.
  2. Review:

    • This policy is reviewed annually to ensure its effectiveness.

Contact

For any questions or concerns related to this policy, please contact our Ethics and Compliance team at

et****@no***********.com











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