Anti-Bribery Policy
1. Introduction
Neutron Pte. Ltd. (“Neutron”) is committed to conducting its business in an ethical and lawful manner and maintaining the highest standards of integrity and transparency. This Anti-Bribery Policy outlines Neutron’s stance on bribery and corruption and sets forth the standards and procedures to prevent, detect, and address bribery and corruption in all our business dealings and relationships.
2. Scope
This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other parties representing or acting on behalf of Neutron (“Employees”).
3. Definition of Bribery and Corruption
Bribery refers to offering, giving, receiving, or soliciting any item of value as a means to influence the actions of an individual or organization in the performance of their duties. Corruption refers to dishonest or fraudulent conduct by those in power, typically involving bribery.
4. Policy Statement
Neutron has a zero-tolerance policy towards bribery and corruption. All forms of bribery and corruption are strictly prohibited, whether they take place directly or through third parties. This includes offering, giving, receiving, or soliciting any form of bribe or improper advantage.
5. Gifts and Hospitality
5.1 Permissible Gifts and Hospitality: Reasonable and proportionate gifts and hospitality offered in good faith, which are customary and appropriate in the circumstances, are generally permissible. However, such gifts and hospitality must not influence, or appear to influence, any business decision or the performance of an individual’s duties.
5.2 Prohibited Gifts and Hospitality: Gifts and hospitality that could be perceived as a bribe or an attempt to influence business decisions are strictly prohibited. This includes, but is not limited to:
- Gifts or hospitality offered during a tender or competitive bidding process.
- Gifts or hospitality that are excessive in value or frequency.
- Gifts or hospitality offered to or received from public officials.
6. Facilitation Payments
Facilitation payments are small, unofficial payments made to expedite or secure the performance of a routine governmental action. Neutron strictly prohibits the making or accepting of facilitation payments.
7. Donations and Sponsorships
All donations and sponsorships made on behalf of Neutron must be transparent, properly documented, and approved by senior management. They must not be used as a subterfuge for bribery.
8. Third-Party Relationships
Neutron expects all third parties acting on its behalf to adhere to the principles set out in this policy. Due diligence should be conducted prior to engaging third parties, and appropriate contractual clauses should be included to ensure compliance with anti-bribery and corruption laws.
9. Record-Keeping
All transactions and expenses must be accurately recorded and maintained in Neutron’s books and records. False, misleading, or incomplete entries are strictly prohibited.
10. Reporting and Whistleblowing
10.1 Reporting: Employees are required to report any suspected or actual bribery or corruption to their supervisor, the Compliance Officer, or through Neutron’s whistleblowing hotline. All reports will be treated confidentially and investigated promptly.
10.2 Protection: Neutron is committed to protecting individuals who report in good faith from retaliation, harassment, or any adverse employment consequences.
11. Training and Awareness
Neutron will provide regular training to all Employees on anti-bribery and corruption laws and this policy. Employees are required to participate in such training and confirm their understanding and compliance with this policy.
12. Consequences of Non-Compliance
Non-compliance with this policy may result in disciplinary action, including termination of employment or engagement, and may also attract legal consequences under applicable anti-bribery and corruption laws.
13. Review and Monitoring
Neutron will regularly review and update this policy to ensure its effectiveness and alignment with applicable laws and regulations. The Compliance Officer is responsible for monitoring the implementation of and compliance with this policy.
14. Governing Laws
This Anti-Bribery Policy and any related matters shall be governed by and construed in accordance with the laws of Singapore. All Employees and third parties are expected to comply with the anti-bribery and corruption laws of Singapore and any other relevant jurisdictions in which Neutron operates.
15. Contact Information
For any questions or concerns regarding this Anti-Bribery Policy, please contact [email protected].