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Introduction
At LiquidQube, we are committed to conducting our business with integrity, transparency, and accountability. We maintain a zero-tolerance approach to bribery and corruption in all forms. This policy outlines our commitment to preventing and addressing bribery and corruption in compliance with applicable laws and regulations, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and equivalent laws in the EU and Brazil.
Scope
This policy applies to all employees, contractors, suppliers, partners, and stakeholders who act on behalf of LiquidQube in any capacity. It governs all activities, regardless of location, and sets clear expectations for ethical behaviour and compliance.
Our Commitment
We are committed to:
Upholding the highest standards of integrity and ethical behaviour.
Complying with all applicable anti-bribery and anti-corruption laws and regulations.
Preventing and addressing bribery and corruption risks within our organisation and supply chain.
Definitions
Bribery: Offering, giving, receiving, or soliciting anything of value as a means of influencing the actions of an individual or organisation inappropriately.
Corruption: Abuse of entrusted power for personal or organisational gain, including fraud, extortion, and embezzlement.
Prohibited Practices
At LiquidQube, the following practices are strictly prohibited:
Bribery
Offering, promising, or giving anything of value to influence the actions of a third party.
Soliciting or accepting bribes, kickbacks, or other improper benefits in exchange for favourable treatment.
Facilitation Payments
Making small payments to expedite routine government actions or services unless legally required.
Conflict of Interest
Engaging in activities or relationships that create a conflict of interest with LiquidQube’s operations or values.
Improper Gifts and Hospitality
Offering or accepting gifts, entertainment, or hospitality that could be perceived as influencing business decisions or creating undue advantage.
Responsibilities
Leadership
Ensure the implementation of this policy across all levels of the organisation.
Promote a culture of integrity and accountability.
Employees
Adhere to the principles of this policy in all business dealings.
Report any suspicions or incidents of bribery or corruption promptly.
Suppliers and Partners
Comply with LiquidQube’s Anti-Bribery and Anti-Corruption Policy as part of our contractual agreements.
Avoid practices that could be construed as bribery or corruption
Reporting and Whistleblowing
LiquidQube encourages all employees, contractors, and stakeholders to report any suspected instances of bribery or corruption. Reports can be made confidentially through our whistleblowing channel at compliance@liquidqubegroup.com.
We are committed to protecting whistleblowers against retaliation and ensuring that all reports are thoroughly investigated.
Monitoring and Enforcement
Regular audits and assessments will be conducted to identify and mitigate bribery and corruption risks.
Non-compliance with this policy will result in disciplinary action, including termination of employment or contracts, and may be reported to relevant authorities.
Training and Awareness
Employees and relevant third parties will receive regular training on anti-bribery and anti-corruption practices.
Resources and guidance will be provided to help individuals recognise and address potential risks.
Compliance with Laws
LiquidQube complies with all applicable anti-bribery and anti-corruption laws, including:
UK Bribery Act 2010
US Foreign Corrupt Practices Act (FCPA)
EU Anti-Corruption Directives
Brazilian Anti-Corruption Law (Law No. 12,846/2013)
Review and Updates
This policy will be reviewed annually to ensure alignment with evolving regulations, best practices, and organisational goals. Updates will be published on our website and communicated to all stakeholders.
Contact Information
For any questions or concerns regarding this policy, please contact the Compliance Department at compliance@liquidqubegroup.com.
