1. Purpose
Invest Offshore is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all our business activities. This Anti-Bribery & Corruption Policy outlines our stance against bribery and corruption and provides guidance to ensure compliance with all applicable laws and regulations.
2. Scope
This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other third parties acting on behalf of Invest Offshore (collectively referred to as “Personnel”). It covers all business dealings and transactions in all jurisdictions where Invest Offshore operates.
3. Definition of Bribery and Corruption
- Bribery is the offering, giving, receiving, or soliciting of something of value (such as money, gifts, favors, or other advantages) to influence the actions of an individual in a position of trust to gain an improper advantage.
- Corruption refers to the abuse of entrusted power for private gain, which can include bribery, embezzlement, fraud, and other forms of unethical conduct.
4. Policy Statements
- Prohibition of Bribery and Corruption
Invest Offshore strictly prohibits all forms of bribery and corruption. Personnel must not offer, give, solicit, or accept any bribes or corrupt payments, whether directly or indirectly, in any form. - Compliance with Laws and Regulations
All Personnel must comply with applicable anti-bribery and corruption laws and regulations in the countries where we operate, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. - Gifts and Hospitality
Offering or accepting gifts, entertainment, or hospitality is generally prohibited, except for nominal and customary gifts of reasonable value that are not intended to influence the recipient’s decision-making. All gifts and hospitality must be reported and approved in accordance with internal guidelines. - Facilitation Payments
Facilitation payments, which are small payments made to expedite routine government actions, are strictly prohibited, regardless of local custom or practice. - Third-Party Relationships
Invest Offshore requires that all third parties acting on our behalf, such as agents, consultants, and contractors, adhere to this policy. Due diligence must be conducted to ensure third parties comply with applicable anti-bribery and corruption laws. - Political Contributions and Charitable Donations
Political contributions and charitable donations must not be used as a subterfuge for bribery. Any contributions or donations made on behalf of Invest Offshore must be legal, transparent, and approved by the relevant management. - Conflicts of Interest
Personnel must avoid any activities or relationships that create a conflict of interest or the appearance of impropriety. All potential conflicts must be disclosed and managed appropriately.
5. Reporting and Whistleblowing
Invest Offshore encourages Personnel to report any suspected violations of this policy or any related laws. Reports can be made confidentially and without fear of retaliation through our established whistleblowing channels. All reports will be investigated promptly and thoroughly.
6. Training and Awareness
All Personnel will receive regular training on anti-bribery and corruption laws and this policy. Training will cover the identification of bribery and corruption risks and how to report concerns.
7. Consequences of Non-Compliance
Violations of this policy may result in disciplinary action, including termination of employment or contract, and may also result in legal consequences. Invest Offshore reserves the right to report any illegal activities to the appropriate authorities.
8. Monitoring and Review
This policy will be regularly reviewed and updated to ensure its effectiveness and alignment with relevant laws and regulations. The Board of Directors is responsible for overseeing the implementation and enforcement of this policy.
Approved by:
Invest Offshore Board of Directors
Effective Date:
August 2, 2024