Anti-bribery policy for suppliers

Purpose of this policy

The purpose of this policy is to set out Qudini’s minimum expectations for complying with anti-bribery laws, and our anti-bribery compliance approach.

Who does this policy apply to?

This policy applies to suppliers that work with, for, or on behalf of Qudini, suppliers include companies, consultants, contractors and agency staff. We have a Qudini Anti-Bribery and Corruption policy that applies to all Qudini employees.

Failure to comply with this policy may result in the termination of contracts with contractors and other third parties working for Qudini or in disciplinary action being taken against aly employees involved.

What is bribery?

Bribery is offering, giving, asking for or receiving anything of value with the intent of getting the recipient to do something improper. Examples of something that is of value include, among other things, offers of cash or a cash equivalent, services, offers of employment, charitable donations, political contributions, travel and/or entertainment expenses, meals and gifts.

A bribe can be anything which is given to get someone to do something wrong, or in respect of public officials, to influence them to our business advantage. Bribery is a criminal offence in most countries. 

Qudini expects and requires that you will not bribe anyone. Equally, if someone asks you to pay a bribe, or offers you a bribe, in connection with our business you must refuse and report it immediately (using one of the methods outlined in this Policy).

Working with us

Qudini may be guilty if a supplier commits an act of bribery on behalf of Qudini, even if Qudini was not aware that the associated party had paid the bribe. As you would expect we only work with suppliers who we are confident will not engage in bribery.

To be a Qudini supplier, and before you start doing any work for us, you must accept our Terms and Conditions relevant to the kind of goods or services you are going to provide, which will require you to comply with this Policy, and agree to comply with our anti-bribery procedures and the law.

Before we on-board suppliers we may decide to carry out due-diligence on the business. We may also carry out further due diligence, whenever necessary, during our relationship.

Facilitation payments

Facilitation payments are bribes (often small sums) made personally to public officials to speed up or make a transaction or administrative process happen (for example, customs clearance). You must not make facilitation payments in connection with our business.

Sometimes these payments are demanded in a threatening way. If you believe that you (or anybody else) would be in danger if you don’t make a payment, we would not expect you to refuse to make it. If you make a payment in these circumstances, tell your Qudini contact as soon as possible.

Gifts and entertainment

For the most part, the giving and receiving of gifts and entertainments is a normal way of developing and maintaining business relationships with suppliers. Gift and entertainment should be modest in nature and only ever an infrequent or occasional activity.

Gifts or entertainment that may be construed as bribes or would cause a conflict of interest or damage the reputation of the business are prohibited and must be avoided at all times. The giving of gifts or entertainment to public officials or their close family members in any country is generally discouraged and gifts are prohibited if they are intended to influence the decisions of a public official or could give that impression.

Political and Charitable Contributions or Donations

As a business we do not have any political affiliations and we do not make political donations. We provide support, both in money and other forms, to qualified non-profit organisations in order to improve the overall well-being of the communities in which we operate.

Charitable contributions or donations must never be provided with the expectation of receiving any improver benefit for Qudini. Donations to charities associated with public officials and their families represent a significant risk for bribery and should be recorded and agreed with your Qudini contact.

Supplier Responsibilities

If you suspect that a breach of this policy has occurred or may occur in the future you must notify your Qudini contact as soon as possible.

We are committed to ensure no one suffers any detrimental treatment because of refusing to take part in bribery or because they have reported in good faith their suspicion that an actual or potential bribery offence has taken place. As long as the reports are made in good faith and the concerns are genuine, suppliers will not be at risk of any form of retribution as a consequence of raising a concern.

Who to contact

If you have any questions or would like additional guidance on how this policy applies or should be implemented please contact your Qudini contact or info@qudini.com.

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