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Anti-Bribery Policy
SAPPHIRE Investigations Bureau Limited ("SAPPHIRE") values its good reputation built up over 4 decades. It is committed to maintaining the highest possible ethical standards in all its business activities. SAPPHIRE recognises that the risks from bribery are a growing concern of corporate and public life in many countries across the world. In its ongoing efforts to maintain its high ethical standards and with a view to upholding its position against any form of bribery, SAPPHIRE has prepared and set out a clear policy which should be implemented in conjunction with the Company's Professional Standards.
Purpose and scope
The purpose of the policy is to set out the responsibilities of all persons associated with the Company, in observing and upholding SAPPHIRE'S position on bribery. It applies to all SAPPHIRE staff worldwide (full-time staff, contract and temporary), within all regions, areas and functions.
Policy
SAPPHIRE prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement:
• To or from any person or company, whether a public official or public body, or a private person or a company, wherever situated; or
• By any individual employee, Agent or other person or company acting on SAPPHIRE'S behalf; or
• In order to gain any commercial, contractual or regulatory advantage for SAPPHIRE in a way which is unethical; or
• In order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
For the avoidance of doubt, SAPPHIRE prohibits the making of any payments to public officials for securing or accelerating routine processes and procedures ("Facilitation Payments").
To further clarify this policy prohibits the making, giving or receiving of any inducement which results in a personal gain or advantage to the recipient or any person or body associated with the recipient, and which is intended to influence the recipient to take action which may not be solely in the best interests of the Company.
Responsibilities
The prevention, detection and reporting of bribery is the responsibility of all employees of SAPPHIRE. If and when any incidence of bribery is identified, remedial steps will have to be taken immediately, including the reporting of the incident of or suspected incident of bribery.
SAPPHIRE Directors should ensure all their employees (also contract and temporary staff) are aware of this policy and of their responsibilities to act in accordance with its procedures.
