Introduction
Infinite Technology is committed to conducting business in a transparent, ethical, and accountable manner. We strictly prohibit any form of bribery and corruption in all our dealings. This Anti-Bribery and Corruption Policy outlines our commitment to preventing bribery and corruption, providing guidance to our employees, contractors, and third parties who work with us, particularly when engaging in public procurement and working within regulated industries in Ireland.
Scope
This Anti-Bribery and Corruption Policy applies to all employees, officers, directors, contractors, suppliers, and any third parties acting on behalf of Infinite Technology. It covers all aspects of our business activities in Ireland, including dealings with public and private sector clients, suppliers, and partners.
Policy Statement
Bribery and corruption in any form are strictly prohibited at Infinite Technology. We uphold the highest standards of integrity in all business interactions, ensuring that we comply with relevant Irish and international laws, including the Criminal Justice (Corruption Offences) Act 2018. We will not offer, give, request, or accept any form of bribe, facilitation payment, or anything of value to gain an unfair advantage in business dealings.
What Constitutes Bribery?
Bribery involves offering, promising, giving, accepting, or soliciting something of value (financial or otherwise) to improperly influence the actions of another person. It may involve:
- Gifts and Hospitality: Excessive or inappropriate gifts and hospitality intended to influence business decisions.
- Facilitation Payments: Payments made to expedite routine services that we are legally entitled to receive.
- Kickbacks: Unethical payments returned to someone who facilitated a deal.
Gifts and Hospitality Guidelines
While giving and receiving modest gifts or hospitality can be part of building good business relationships, these actions should never influence, or be seen to influence, decision-making processes. Employees must:
- Ensure that any gifts or hospitality are appropriate and do not exceed reasonable value.
- Report any gifts or hospitality received or offered to our compliance officer if they exceed the established thresholds.
- Avoid accepting gifts, hospitality, or entertainment during public procurement processes or contract negotiations.
Facilitation Payments
Facilitation payments, even when culturally accepted, are prohibited by Infinite Technology. These small, unofficial payments are made to secure or speed up routine actions or services. Any requests for such payments must be reported immediately to the compliance officer.
Responsibilities
All employees and associated parties must adhere to this policy and play a role in preventing, detecting, and reporting potential bribery and corruption.
- Employees: Must report any suspected cases of bribery or corruption and comply with this policy in their day-to-day activities.
- Management: Is responsible for ensuring that anti-bribery measures are implemented and that all employees receive appropriate training.
- Compliance Officer: Oversees the anti-bribery program, monitors compliance, and investigates any suspected breaches.
Third-Party Engagement
We expect all third parties acting on behalf of Infinite Technology to adhere to similar anti-bribery and corruption standards. Contracts with third parties will include provisions for compliance with anti-bribery laws, and we will conduct due diligence to assess the risk of bribery and corruption.
Reporting and Whistleblowing
Employees, partners, and third parties are encouraged to report any concerns related to potential bribery or corruption. Infinite Technology will treat all such reports confidentially and ensure that there will be no retaliation against anyone who makes a report in good faith.
Record-Keeping
All financial records, transactions, contracts, and arrangements must be accurately maintained and reflect the true nature of the business activities. This includes clear documentation of any gifts, hospitality, or expenses.
Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment. In cases where bribery or corruption has occurred, individuals may also face legal prosecution under Irish law.
Policy Review
This policy shall be reviewed annually or in response to changes in relevant laws or business circumstances to ensure continued effectiveness and compliance.