Anti-Corruption and Anti-Bribery Policy

1. Introduction

This policy outlines Cecure Intelligence Limited's commitment to conducting business with integrity and in full compliance with all applicable anti-corruption and anti-bribery laws and regulations worldwide. This includes, but is not limited to, the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and other similar legislation globally.

2. Policy Statement

Cecure Intelligence Limited strictly prohibits all forms of corruption and bribery. This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other parties working for or on behalf of Cecure Intelligence Limited, wherever they are located.

3. Definitions

• Bribery: Offering, promising, giving, accepting, or soliciting anything of value with the intent to improperly influence a decision or outcome.
• Corruption: The abuse of entrusted power for private gain. This includes bribery, extortion, fraud, and embezzlement.
• Anything of Value: Can include, but is not limited to, cash, gifts, entertainment, travel expenses, charitable donations, political contributions, job offers, or any other benefit or advantage.

4. Prohibited Conduct

All individuals covered by this policy are prohibited from:

• Offering, giving, or promising anything of value, directly or indirectly, to any government official, public official, or private individual with the intent to improperly influence an act or decision.
• Requesting or accepting anything of value, directly or indirectly, from any party with the intent to improperly influence a decision or outcome related to Cecure Intelligence Limited's business.

5. Gifts, Hospitality, and Entertainment

While reasonable and proportionate gifts, hospitality, and entertainment can be a legitimate part of business, they must never be used to influence a business decision or gain an unfair advantage improperly.

• All gifts, hospitality, and entertainment must be:
  • Lawful and compliant with local laws and regulations.
  • Reasonable in value and frequency.
  • Provided openly and transparently, not secretly.
  • Recorded accurately in Cecure Intelligence Limited's books and records.
• Prior approval is required for gifts, hospitality, or entertainment exceeding a specific value, as outlined in the company's detailed Gifts and Hospitality Policy.

6. Facilitation Payments

Facilitation payments (small payments to secure or speed up routine government actions) are strictly prohibited, even if they are standard practice in a particular country.

7. Due Diligence

Cecure Intelligence Limited will conduct appropriate due diligence on all third parties (e.g., agents, consultants, joint venture partners) to ensure they share our commitment to anti-corruption and anti-bribery principles.

8. Accurate Books and Records

All financial transactions, including those related to gifts, hospitality, travel, and expenses, must be accurately and transparently recorded in Cecure Intelligence Limited's books and records. No off-the-books accounts or false entries are permitted.

9. Training and Awareness

Regular training will be provided to all relevant employees and third parties to ensure they understand their obligations under this policy and applicable anti-corruption laws.

10. Reporting Violations and Non-Retaliation

• Any actual or suspected violations of this policy or anti-corruption laws must be reported immediately to Cecure Intelligence Limited's Legal Domain or through the designated confidential reporting channel.
• Cecure Intelligence Limited is committed to protecting individuals who report concerns in good faith from retaliation.

11. Consequences of Non-Compliance

Violations of this policy will result in disciplinary action, up to and including termination of employment or contract. They may also lead to civil and criminal penalties for individuals and the company.

12. Policy Review

This policy will be reviewed periodically by Cecure Intelligence Limited's leadership and Legal Domain to ensure its continued effectiveness and compliance with evolving laws and regulations.

13. Contact Information

For any questions regarding this policy, please contact info@cecureintel.com.