Anti-Bribery and
Anti-Corruption Policy

Anti-bribery & Anti-corruption’s policy reflects
the Company’s efforts to implement and to
enforce aneffective system to counter bribery and corruption activities.

FraudLens is committed to manage and to conduct the entire business in honest and ethical manner. The fundamental standards of integrity under which FraudLens operates strictly prohibits bribery or other improper payments in any of its business operations.

This policy is designed to reduce the risk of bribery and corruption activities occurring and their criminal and reputational impact on FraudLens and parties FraudLens contracts with.


FraudLens does not tolerate practices of bribery and corruption in any form or wherever paid. It is the responsibility of all employees who are involved at any time in engaging the services of external bodies (consultants, suppliers or advisers, etc.) to ensure that such individuals are made aware of the content of FraudLens Anti-Bribery and Anti-Corruption policy at the outset of the relationship and on a regular basis thereafter.

This Policy Covers:

1-Bribes and kickbacks

Bribery involves the following:
  • When a financial or other advantage is offered, given, or promised to any stakeholder with an intention to reward them to perform their duties and responsibilities improperly.
  • When a financial or other advantage is requested, agreed to be received or accepted by another person with the intention to reward them to perform their duties and responsibilities improperly.
Bribes can take many forms, for example:
  • Money (cash or cash equivalent,); Unreasonable gifts, entertainment or hospitality;
  • A typical indirect bribery would be a case where a company employs a commercial agent to help it win a deal. The agent is paid by commission based on a percentage of the deal revenues, and part of that commission is passed on to a third agent.

Kickbacks arise when suppliers or service providers pay part of their fees to the individuals who give them the contract or some other business advantage.
It does not matter whether the bribe is offered or requested directly or through a third party.
The company prohibits its employees from engaging in acts of corruption, and from paying bribes or kickbacks to, or accepting bribes or kickbacks from, public officials and private individuals such as the personnel of companies with which the company does business.

2-Facilitation payments

Facilitation payments are any payments, no matter how small or in which form given to another person or received by other person to increase the speed at which they do their job, or to get a business details that might have financial impact on business and/or personal level. Examples include payments to obtain clients; selecting suppliers, accelerate visa processing, etc.
Facilitation payments are prohibited. Staff must report any incident where they feel forced to make a facilitation payment to their line manager at the earliest opportunity. The company will stand by employees who find themselves placed in exceptional situations provided that the employee has provided absolute transparency as to the circumstances surrounding a payment shortly after the incident has occurred.

3-Public officials

Bribing or corrupting a public official is a serious offence, can carry severe penalties and can cause significant reputational damage. This policy provides detailed guidelines on gifts and hospitality.
Approval must be secured in advance in relation to gifts or benefits received from or offered to public officials, particularly the giving of anything of value to a public official.

4-Gifts, hospitality and Expenses

Company employees may not offer to, or accept from, third parties, gifts, hospitality, rewards, benefits or other incentives that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty.
Similarly, they may not offer or accept cash donations. Company employees may offer and accept ‘reasonable’ and ‘proportionate’ gifts and entertainment, such as dinner, theatre parties or sporting events, which should need Management’s permission as per Delegation of Authority.
In determining, what is ‘reasonable’ and ‘proportionate’, employees should consider the value of the gift or benefit (see below), as well as the frequency with which the same or similar gift or benefit is offered. In all cases they must ensure that the gift or benefit:

Employees must seek prior approval as per the Delegation of Authority from their Department heads for all gifts or benefits received or offered with a value of more than USD 100 (or equivalent) prior to final acceptance. Approval must be given in writing, and records of gifts received, from whom and by whom, must be recorded in an office or function log established for such purpose.

5-Personal conflicts of interest

Company employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of the company.
This includes: acting on any client information gained through their employment with the company for personal gain; passing such information to a third party; or acting in any way that could be construed as insider trading.
Conflicts of interest can arise if individuals have a personal interest in business dealings involving the company. Personal interest can be direct or indirect, and refers not only to personal interests but to those of family members and friends. If there is a potential for conflict, the interests of the company must take priority.
Employees must disclose any personal conflict of interest or perceived conflict to their line manager.

6-Charitable donations

As part of its corporate citizenship activities, FraudLens may support local charities or provide sponsorship, for example, to sporting or cultural events. Any such sponsorship must be transparent and properly documented. FraudLens will only provide donations to organizations that serve a legitimate public purpose, and which are themselves subject to high standards of transparency and accountability. Appropriate due diligence must be conducted on the proposed recipient charity and a full understanding obtained as to its bona fides.