Anti-Bribery Policy

  1. What does your policy cover?
    1.1 This anti-bribery policy exists to set out the responsibilities of Quant Foundry Limited and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.
    1.2 It also exists to act as a source of information and guidance for those working for Quant Foundry Limited. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
  2. Policy statement
    2.1 Everyone who works at Quant Foundry Limited is committed to conducting business ethically and honestly. We are committed to implementing and enforcing systems that ensure we prevent bribery. Quant Foundry Limited has zero-tolerance for corruption and corrupt activities. We are committed to acting professionally and with integrity in all business dealings and relationships, wherever in the country we operate.
    2.2 We will uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are compliant to the law of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.
    2.3 Quant Foundry Limited recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face severe damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.
  3. Who is covered by the policy?
    3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK).
    3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with us. It applies to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials.
    3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.
  4. Definition of bribery
    4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or .of an advantage so to induce or influence an action or decision.
    4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.
    4.3 Bribery is not limited to the act of providing a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
    4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes to any degree. If they are uncertain about whether something is
    a bribe or a gift or act of hospitality, they must seek further advice from the company’s managing directors
    4.5 Quant Foundry Limited view kickbacks as one manifestation of bribery
  5. What is and what is NOT acceptable
    5.1 Gifts and hospitality
    Quant Foundry Limited accepts normal and appropriate gestures of generosity, hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meet the following requirements:
    a. The intention is not to influence the recipient to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
    b. No suggestion that the recipient should return the favour.
    c. It complies with local law.
    d. It is given in the name of the company, not in an individual’s name.
    e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
    f. Appropriate for the circumstances (e.g. giving small gifts around Christmas or as a token thank you to a company for helping with a large project upon completion).
    g. Appropriate type and value, taking into account the reason for the gift.
    h. The giver and receiver operate openly, not secretly.
    i. The giver is not being selective to an influential person with the intention of directly influencing them.
    j. It is not above £250
    k. The recipient is no a government official or representative or politician or political party.
    5.2 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a religion/culture who may take offence), the recipient may accept the gift and declare the gift to the managing directors.
    5.3 Quant Foundry Limited recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
    5.4 The recipient must disclose all gifts from suppliers to the managing directors
    5.5 The recipient must review the intention behind a gift and discuss with the managing directors for clarity.
    5.6 Quant Foundry Limited does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We understand that they tend to be made by low-level officials with the intention of securing or speeding up an activity
    5.7 Quant Foundry Limited does not allow kickbacks to be made or accepted.
    5.8 Quant Foundry Limited recognises that, despite our strict policy on facilitation payments and bribes, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the recipient must follow steps: –
    a. Keep the amount to the minimum.
    b. Ask for a receipt, detailing the amount and reason for the payment.
    c. Record the payment and report this incident to the managing directors
    5.9 Political Contributions
    Quant Foundry Limited will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates.
    5.10 Charitable Contributions
    Quant Foundry Limited accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
    5.11 Employees must be careful to ensure that charitable donations are not used to facilitate and conceal acts of bribery.
    5.12 We will ensure that donations made are legal and ethical under local laws and practices.
  6. Employee Responsibilities
    6.1 All employees must ensure that you read, understand, and comply with the information contained within this policy.
    6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
    6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.
    6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Quant Foundry Limited has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
  7. What happens if I need to raise a concern?
    7.1 If you suspect that there is an instance of bribery or corrupt activities occurring, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether an action or behaviour can be considered bribery or corruption, you should speak to either managing director. All employees can vocalise their concerns swiftly and confidentially and directly to the managing directors.
    7.2 If you are a victim of bribery or corruption, you must tell a managing director as soon as possible. If someone offers you a bribe or asks you to make one, or if you have reason to believe that you are a victim of another corrupt activity.
    7.3 If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption. Quant Foundry Limited understands that you may feel worried about repercussions. We will protect anyone who raises concerns in good faith under this policy, even if an investigation finds that they were mistaken.
    7.4 Quant Foundry Limited will ensure that no one suffers any detrimental treatment (such as being dismissed) as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. The managing directors review all cases associated that include bribery.
  8. Training and communication
    8.1 Quant Foundry Limited provides training on this policy as part of the induction process for all new employees. Employees will also receive annual, relevant training to certify adherence to this policy.
    8.2 Quant Foundry Limited communicates its anti-bribery and corruption policy and zero-tolerance attitude to all suppliers, contractors and business partners
  9. Record keeping
    9.1 Quant Foundry Limited keeps detailed and accurate financial records to act as evidence for all payments made. We will declare and maintain a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts are subject to managerial review.
  10. Monitoring and reviewing
    10.1 The managing directors are responsible for monitoring the effectiveness of this policy and will review the implementation annually.
    10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits.
    10.3 Employees are encouraged to offer their feedback to the managing directors on this policy if they have any suggestions for how it may be improved.
    10.4 This policy does not form part of an employee’s contract of employment and Quant Foundry Limited may amend it at any time so to enhance its effectiveness at combatting bribery and corruption.