2. Scope

This policy applies to all employees, contractors, consultants, agents, and any other third parties acting on behalf of Digitalogy Ltd. It covers all business dealings, transactions, and interactions with government officials, private entities, and individuals globally.

3. Definition of Bribery

Bribery involves offering, giving, receiving, or soliciting anything of value to influence the actions of an individual in a position of trust. Examples of bribery include:

Offering or accepting money, gifts, or favours to secure a business advantage.

Making facilitation payments to expedite or secure routine government actions.

Providing extravagant hospitality or entertainment to influence decision-making.

4. Policy Statement

Digitalogy Ltd prohibits:

The offering, giving, soliciting, or accepting of bribes in any form.

Facilitation payments or “grease payments” intended to expedite routine services.

Any form of corrupt activity, directly or indirectly, through third parties.

We require all employees and associates to act with integrity and adhere to this policy, regardless of local customs or business practices.

5. Responsibilities

Leadership Team: Ensure the implementation and enforcement of this policy across the organisation.

Employees and Associates: Understand and comply with the policy and report any suspected bribery or corruption.

Anti-Bribery Officer (ABO): Oversee compliance with the policy, provide training, and handle investigations into alleged breaches.

6. Gifts and Hospitality

While gifts and hospitality can foster good relationships, they must never be used to influence business decisions. The following guidelines apply:

Permitted: Modest, appropriate gifts and hospitality that comply with local laws and company procedures.

Prohibited: Extravagant or frequent gifts and hospitality intended to influence or reward decisions.

All gifts and hospitality must be recorded in the Gifts and Hospitality Register.

7. Third-Party Relationships

Digitalogy Ltd expects all third parties acting on its behalf to comply with this Anti-Bribery Policy. We will:

Conduct due diligence on third parties to assess bribery and corruption risks.

Include anti-bribery clauses in contracts with third parties.

Monitor third-party activities to ensure compliance with this policy.

8. Training and Awareness

We provide regular training to employees to ensure:

Awareness of the risks of bribery and corruption.

Understanding of their responsibilities under this policy.

Knowledge of how to report concerns or breaches.

9. Reporting and Whistleblowing

Employees and associates are encouraged to report any suspected bribery or corruption immediately to the Anti-Bribery Officer. Reports can be made confidentially and without fear of retaliation through our whistleblowing procedure.

10. Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts. In addition, individuals involved in bribery or corruption may face criminal prosecution and penalties.

11. Monitoring and Review

This policy will be monitored and reviewed annually or as necessary to ensure its effectiveness and alignment with legal and regulatory requirements. Updates will be communicated to all employees and stakeholders.