1. Introduction

It is the policy of Virtual Trader (the Company) to conduct business in an honest and ethical manner. The Company therefore takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships. Wherever the Company operates, it implements and enforces effective systems to counter bribery.

The Company upholds all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business; these include the Foreign Corrupt Practices Act 1977 in the U.S. and the Bribery Act 2010 in the UK.

Bribery and corruption conducted by individuals is an offence that is punishable by imprisonment. If the Company is found to have taken part, it could face an unlimited fine and experience significant damage to its reputation. The Company therefore takes its legal responsibilities seriously.

2. Purpose

The purpose of this policy is to:

• Publicly communicate the Company's position and responsibilities in respect of bribery and corruption.
• Provide information and guidance to those who provide work for the Company on how to recognise and deal with bribery and corruption issues.

3. Applicability

This policy applies to all individuals working for or on behalf of the Company at all levels and grades, whether permanent, fixed-term, or temporary, and wherever located, including consultants, contractors, seconded staff, and any other person who performs work under the control of the Company (collectively referred to as workers in this policy).

In this policy, third party means any individual or organisation that workers come into contact with during the course of work and the running of the Company's business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives, and officials), politicians, and political parties.

The Company may also be liable under the Act(s) if it fails to prevent bribery by an associated person (including but not limited to workers) for the Company's benefit.

4. What are Corruption and Bribery?

The Company accepts the following definitions:

• Corruption is the misuse of office or power for private gain.
• A bribe is an inducement or reward offered, promised, or provided to improperly gain any commercial, contractual, regulatory, or personal advantage.

5. Gifts and Hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from third parties unless otherwise specifically stated. However, any gift or hospitality must not be made with the intention of improperly influencing a third party or worker to obtain or retain business or a business advantage or in explicit or implicit exchange for favours or benefits.

Any gift or hospitality:

• Must comply with local law in all relevant countries.
• Must be given in the name of the organisation, not in an individual’s name.
• Must not include cash or a cash equivalent.
• Must be appropriate in the circumstances.
• Must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift.
• Must be given openly, not secretly.
  
  

The Company appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether, in all the circumstances, the gift or hospitality is reasonable and justifiable in the respective jurisdiction. The intention behind the gift should always be considered.

6. What Is Not Acceptable

It is not acceptable for any worker (or someone on their behalf) to:

• Give, promise to give, or offer a payment, gift, or hospitality with the expectation or hope that they or the Company will improperly be given a business advantage or as a reward for a business advantage already improperly given.
• Give, promise to give, or offer a payment, gift, or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure.
• Accept a gift, hospitality, or payment from a third party where it is known or suspected that it is offered or given with the expectation that the third party will improperly obtain a business advantage.
• Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.
• Engage in any activity that might lead to a breach of this policy.

7. Facilitation Payments and Kickbacks

The Company will neither make nor accept facilitation payments or kickbacks of any kind, such as small, unofficial payments made to secure or expedite a routine action or payments made in return for a business favour or advantage.

8. Accounting and Record Keeping

The Company maintains appropriate financial records and has internal controls in place to evidence the business reason for gifts, hospitality, and payments made and received.

9. Responsibilities and Raising Concerns

The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under its control. All workers are required to avoid any activity that might lead to or suggest a breach of this policy.

Workers are required to notify the Company as soon as possible if it is believed or suspected that a conflict with this policy has occurred (or may occur in the future) or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any worker who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. The Company reserves the right to terminate its contractual relationship with non-employee workers if they breach this policy.

If any third party is aware of any activity by any worker that might lead to or suggest a breach of this policy, they should raise their concerns with the Company CEO.

10. Training and Communication

Training on this policy is provided annually for all workers, and the Company's zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors, and business partners.

Updated: November 08, 2022