Kore Dev: Anti-Bribery Policy

1. Purpose

The purpose of this Anti-Bribery Policy is to ensure that Kore Dev conducts its business in an honest and ethical manner. This policy outlines our zero-tolerance approach to bribery and corruption and provides guidelines to prevent, detect, and address bribery in all its forms.

2. Scope

This policy applies to all employees, directors, freelancers, agents, and any other third parties acting on behalf of Kore Dev. It covers all business dealings and transactions in all countries in which Kore Dev operates.

3. Definition of Bribery

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. Advantages can take various forms, including money, gifts, loans, fees, hospitality, services, discounts, or other benefits.

4. Legal Framework

This policy is guided by relevant legislation and best practices, including but not limited to:

• The Bribery Act 2010 (UK)
• The Foreign Corrupt Practices Act (FCPA) (US)
• The United Nations Convention against Corruption (UNCAC)

5. Policy Statement

Kore Dev strictly prohibits:

• The offering, giving, or receiving of bribes or improper payments to obtain or retain business or any other advantage.
• The use of third parties to engage in bribery or corrupt practices on our behalf.
• Any form of facilitation payments, which are small payments made to expedite routine government actions.

6. Gifts and Hospitality

• Gifts and hospitality must be reasonable, proportionate, and not intended to influence business decisions.
• All gifts and hospitality given or received must be reported to the Director, Robert Hatcher.
• Lavish or extravagant gifts or hospitality are strictly prohibited.

7. Charitable Donations and Sponsorships

• All charitable donations and sponsorships must be transparent, lawful, and not used as a disguise for bribery.
• Donations and sponsorships must be approved by Director – Robert Hatcher and recorded in the company’s financial records.

8. Political Contributions

• Kore Dev does not make political contributions. Employees may participate in political activities in their personal capacity but must not use company resources or imply company endorsement.

9. Responsibilities

9.1. Management

• Ensure this policy is communicated and implemented throughout the organisation.
• Monitor and review compliance with this policy regularly.

9.2. Employees

• Comply with the principles and requirements of this policy.
• Report any suspected or actual bribery or corruption incidents.

10. Reporting and Whistleblowing

• Employees are encouraged to report any concerns or suspicions of bribery or corruption.
• Reports can be made confidentially to the Director.
• No employee will suffer retaliation for reporting concerns in good faith.

11. Consequences of Non-Compliance

• Any employee found to be in breach of this policy will face disciplinary action, which may include termination of employment.
• Third parties acting on behalf of Kore Dev who breach this policy may have their contracts terminated.
• Kore Dev will cooperate with law enforcement authorities in the investigation and prosecution of bribery and corruption cases.

12. Awareness

• Employees are required to acknowledge their understanding and compliance with this policy.

13. Monitoring and Review

• Kore Dev will regularly monitor the effectiveness of this policy and report findings to the Director.
• This policy will be reviewed annually and updated as necessary to reflect changes in legislation or organisational practices.

14. Contact Information

For questions or concerns regarding this policy, please contact the Director, Robert Hatcher on 0117 428 6812.