Tracepos Anti-Bribery and Corruption (ABC) Policy

1.0 Purpose

Tracepos Technologies Limited ("Tracepos" or "the Company") is committed to conducting its business ethically and in full compliance with all applicable laws and regulations. This policy outlines our zero-tolerance stance towards bribery and corruption in all its forms.

The purpose of this policy is to:

  • Set out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on bribery and corruption.
  • Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

2.0 Scope

This policy applies to all individuals working at all levels and grades, including directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, or any other person associated with us, wherever located (collectively referred to as "staff" in this policy).

3.0 Policy Statement

Tracepos strictly prohibits any form of bribery or corruption. We will not, directly or indirectly, offer, promise, give, request, or accept a bribe or any other improper advantage to or from any person or entity in order to gain a business advantage, influence a decision, or as a reward for improper performance.

4.0 What is Bribery and Corruption?

Bribery: The act of offering, giving, promising, asking, agreeing to receive, or accepting something of value (a "bribe") to influence the actions of an individual in the discharge of their public or legal duties.

Corruption: The abuse of entrusted power for private gain.

This includes, but is not limited to:

  • Facilitation Payments: Small, unofficial payments made to secure or expedite a routine government action by a government official. These are strictly prohibited.
  • Kickbacks: Payments made in return for a business favour or advantage.

5.0 Gifts and Hospitality

This policy does not prohibit normal and appropriate gifts, hospitality, entertainment, and promotional expenditures, so long as they are:

  • Given in good faith and not intended to influence a decision.
  • Given openly and transparently.
  • Of a modest and reasonable value.
  • Not in the form of cash.
  • Permitted under local laws.

All staff must use proper judgment. Any gift or hospitality that is, or could be perceived as, excessive or intended to create an improper obligation must be declined and reported to management.

6.0 Responsibilities

The Board of Directors (Management): Has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

All Staff: All staff are responsible for understanding and complying with this policy. Every employee has a duty to prevent, detect, and report any instances of bribery or corruption.

7.0 Reporting (Whistleblowing)

We encourage all staff to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are aware of or suspect that any form of bribery or corruption has occurred, is occurring, or is likely to occur, you must notify your manager or a Company Director immediately.

Tracepos is committed to ensuring no one suffers any detrimental treatment (such as dismissal, disciplinary action, or threats) as a result of refusing to take part in bribery or corruption, or for reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place.

8.0 Monitoring and Review

The Board of Directors will monitor the effectiveness and review the implementation of this policy regularly, considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible.

9.0 Contact Information

For any questions or concerns regarding this policy or our ethical practices, please contact us at:

Tracepos Technologies Limited
Email: [email protected]
Website: https://www.tracepos.net