Anti-Bribery and Corruption Policy
As adopted August 25, 2021
I. GENERAL OVERVIEW
Evidation Health, Inc. (collectively with its subsidiaries, “Evidation”, “we”, “our” or “us”) and every director, officer, employee, independent contractor and consultant of ours (which we refer to collectively as “employee(s)”) is committed to promoting high standards of ethical business conduct, integrity, transparency, and compliance in our business dealings. We strive always to ensure compliance with our Code of Conduct and company policies, as well as applicable laws, rules and regulations, and live our values by putting in place and maintaining an effective and comprehensive compliance program (referred to as Evidation’s “Compliance and Ethics” program) to prevent and detect violations of law or company policy. As part of this commitment, all Evidation employees, representatives, and service providers, whether located in the U.S. or worldwide, are required to comply with the Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act (the “UKBA”), other anti-bribery laws, local laws, and this Anti-Bribery and Corruption Policy (this “Policy”), as well as any procedures developed to implement this Policy.
A. What This Policy Covers & Why. We are committed to complying with all applicable laws, executive orders, and regulations described in this Policy. We also seek to maintain a reputation that meets robust ethical and legal standards. No Evidation employee, representative, or service provider, or any other third parties we engage, is authorized to undertake, or condone the undertaking, of any conduct prohibited or restricted under applicable laws or this Policy. This Policy applies to all of our employees, representatives, and service providers, each of whom is responsible for protecting us from legal exposure and for avoiding any situation that might compromise the reputation of Evidation or our personnel, partners, and stakeholders.
The purpose of this Policy is to:
- set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and
- provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues.
Evidation’s employees, representatives, and service providers must be aware that it is a criminal offence in the United States, the United Kingdom, and most other countries, to offer, promise, give, request, or accept a bribe or to engage in corrupt activity. Individuals found guilty can be imprisoned and/or fined. If we fail to prevent bribery, we can face an unlimited fine, exclusion from tendering contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously and expect you to do so as well.
B. Representative & Service Provider Compliance Required. An employee responsible for engaging or managing the relationship with a company representative or third-party service provider on behalf of Evidation must ensure the third party is aware of this Policy and complies with it and Evidation’s Code of Conduct, as well as all other Evidation policies and processes that may apply to that entity or the work they are providing on our behalf.
C. Manager Responsibility. Managers should help ensure awareness, receipt and timely completion of all assigned training, including training on our Compliance and Ethics program, and any policies or procedures relevant to the specific tasks or activities that employees are performing on Evidation’s behalf. A manager who becomes aware of suspected misconduct has a duty to report the matter through available channels.
D. Other Related Policies. Other related company policies, such as Evidation’s Speak Up Policy and Code of Conduct, may also apply and must be followed. Additional information and guidance about this Policy may be found in the attached Anti-Corruption FAQs.
III. GUIDELINES FOR COMPLIANCE UNDER THIS POLICY
A. Expectations. Evidation does not, and prohibits its employees, representatives, and service providers from, directly or indirectly, authorizing, making, offering, promising, requesting, receiving or accepting bribes, kickbacks, or other improper payments in any form. This prohibition applies to all forms of bribery including commercial bribery as well as bribery of government officials. Evidation expects its employees, representatives, and service providers to be aware that U.S. and other anti-corruption laws prohibiting bribery are very broad, so that many kinds of gifts or entertainment provided to government employees, authorities, or other public officials (referred to herein as “government official”) might be considered improper. For that reason, you may not give anything of value to any government official in order to wrongfully influence the government official, obtain or retain business or receive any improper advantage. This prohibition applies regardless of whether the gift, payment or offer of payment is made directly to the government official or indirectly through a third party.
Examples of prohibited conduct include, without limitation:
- payments made directly to a government official for an improper advantage;
- payments or gifts to third parties where you know or have reason to know that at least a portion of the payments or gifts is likely to be offered by the third party to a government official for an improper advantage;
- acts “in furtherance of” an improper advantage, such as arranging for funds to be available for the improper advantage; and
- payments to retain assets, such as an “under the table” payment to a tax official to settle a tax claim or to a regulatory official to obtain or expediate regulatory approval.
Evidation and its employees, representatives, and service providers must also avoid even the appearance of impropriety under this Policy, as actions and activities that could be construed as providing us with an improper advantage could jeopardize the trust we have built with our customers, partners, and regulators, and result in investigations and potential civil or criminal liability. If you have any questions about whether a payment, gift, offer or other act may be improper or violate this Policy, consult the Compliance Officer (as defined in the Company’s Code of Conduct) before making any such payment, gift or offer or engaging in such other act.
B. Important Concepts.
“Bribery” is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
“Corruption” is the abuse of entrusted power or position for private gain.
“Government official” includes:
- any official or employee of a government, including any political party, administrative agency, or government-owned business;
- any person acting in an official capacity on behalf of a government entity;
- employees or agents of a business which is owned or controlled by a government;
- any person or firm employed by or acting for or on behalf of any government;
- any political party official, employee or agent of a political party, or candidate for political office (or political party position); and
- any family member or other representative of any of the above.
Any doubts about whether a particular person is a government official should be resolved by assuming that the individual involved is a government official for purposes of anti-corruption laws.
“Anything of value” includes money (including charitable or political contributions, loans or non-arm’s length transactions) and monetary equivalents (such as gambling chips and gift cards), products (including our products or subscriptions), entertainment, accommodations, and any other benefit (such as business, employment or investment opportunities). There is no “minimum” required under the FCPA or UKBA – any amount can be sufficient to trigger a violation.
“Improper advantage or purpose” includes payments intended to wrongfully:
- influence a decision by an official, including a failure to perform his or her official functions;
- induce an official to use his or her influence to affect a decision by someone else in his or her government; and
- induce an official to use his or her influence to affect or influence any act or decision.
In addition to obtaining or retaining business, “improper advantage” includes reducing taxes or duties, “looking the other way” at minor code or rule violations, and any form of preferential treatment.
“Third party” means any individual or organization you come into contact with during the course of your work for Evidation, and includes any representative, vendor, service provider, agent, partner, independent contractor, consultant, collaborator, manufacturer, university, contract manufacturer, research facility, other actual and potential client, customer, supplier, distributor, business contact, adviser, and government and public body, including their advisors, representatives and officials, politicians and political parties.
C. Gifts, Entertainment, Travel & Promotional Expenditures. Gifts in the business context can be an appropriate way to display respect for each other. We expect the use of good judgment and moderation when giving or receiving entertainment or gifts. However, no gift or entertainment should ever be offered, given, provided or accepted by you unless it meets all of the following
- is not cash;
- is reasonable and not extravagant;
- is appropriate under the circumstances and serves a valid business purpose;
- is consistent, customary and appropriate under U.S. and local business practices;
- is not being offered for any improper purpose, and could not be construed as a bribe, kickback or payoff;
- does not violate any of our policies;
- does not violate any U.S., local or international laws or regulations; and
- is accurately and timely described in expense or other reports and our books and records after the gift is given or entertainment provided.
i. Accurate Reporting of Expenditures. Any expenditures for gifts or entertainment made by or on behalf of Evidation must be timely and accurately reported to the Finance Department and other personnel to ensure the purpose, amount, and recipient of the gift are obvious (i.e., transparent). Such expenditures are subject to internal review and auditing. Expense reports should accurately state the purpose of the expenditures and the identities of the individuals receiving the gift or entertainment and must specifically state whether the gift or entertainment was given to a government official or to any employee of a government entity.
ii. Additional Restrictions Apply to Gifts, Entertainment, or Other Expenditures made to Government Officials. Because significant legal restrictions apply with regard to providing gifts, entertainment, travel, and promotional expenditures related to government officials, it is generally advisable to seek guidance from your manager or the Compliance Officer prior to providing any gift, entertainment, or other monetary or non-monetary remuneration to a government official. Prior to engaging in any such conduct, you must make sure you fully understand all such restrictions and associated policies and procedures. In each instance:
- all gifts, entertainment, or promotional expenses intended to induce a government official to misuse his or her position or to obtain an improper advantage are prohibited, regardless of their value;
- expenses must have a valid business purpose and be reasonable and necessary under the circumstances;
- gifts must be of token value (such as shirts or tote bags that reflect Evidation’s business name and/or logo), legal and customary, and openly given; and
- expenses and gifts must be fully, accurately and timely reflected in our books and records and backed by receipts.
You should avoid even the appearance of impropriety. Any gift or expense that is lavish, against the law or this Policy, or might otherwise prove embarrassing for Evidation is prohibited. If you have any question regarding the appropriateness of any gift or expense, you should consult your manager, or the Compliance Officer prior to giving the gift or incurring the expense.
iii. Additional Restrictions Apply to Gifts, Entertainment, or Other Expenditures made to Healthcare Professionals (“HCPs”) and Healthcare Organizations (“HCOs”).
Certain federal and state U.S. laws and regulations, and the laws of foreign countries in which we do business, impose limitations on interactions with certain individuals and entities in the healthcare space, namely HCPs and HCO employees, because of heightened concerns and risks related to bribery, corruption, and unlawful influence, among other considerations. These laws and regulations impose limitations on transfers of value (i.e., compensation, travel, meals, gifts, etc.) to HCPs and HCO employees and place transaction transparency disclosure requirements on Evidation to the extent we partner or do business with HCPs and HCOs. As a general rule, Evidation does not, and prohibits its employees, representatives, and service providers from, providing or offering to HCPs or HCO employees on Evidation’s behalf:
- promotional items, regardless of value and whether they are Evidation-branded, such as pens, notepads, t-shirts, or coffee mugs;
- items for personal use (e.g., cash or cash equivalents (such as gift cards) or physical gifts such as flowers or gift baskets), even if the gift is intended to recognize a significant life event such as a birthday or promotion; and/or items that are capable of use by the recipient’s family member, office staff, or friends for non-educational or non-patient-related purposes; and
- meals and refreshments, other than in connection with legitimate business meetings, and then only under specific circumstances and in accordance with certain requirements.
Due to the complicated nature of interacting with HCPs and HCOs, if you would like to provide a gift, entertainment, or other transfer of value, or otherwise engage in one of the activities described in this Section, first seek guidance from your manager, the Compliance Officer, or direct your question to the Speak Up Hotline or the web or mobile site set forth in the Speak Up Policy. For the avoidance of doubt, this Policy is not intended to prevent the occurrence of the aforementioned activities in your personal capacity, so long as the conduct or activity is not on behalf of, for the benefit of, sponsored by, or otherwise in the furtherance of or connected to Evidation.
D. Facilitating Payments. Facilitating payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). The FCPA and other anti-bribery laws may provide limited exceptions for certain facilitating payments. However, other anti-corruption laws may prohibit such payments. Any and all facilitating payments require prior written approval from the Compliance Officer.
E. Representatives, Partners, Consultants, Distributors, Agents, and Other Third Parties. Before initiating a relationship with a representative, partner, consultant, distributor, agent, service provider, or other third party on behalf of Evidation, you must conduct appropriate due diligence to assure yourself that the representative will not engage in any improper conduct and will abide by Evidation’s policies and processes that apply to the proposed business activities or project. Due diligence typically will include considering such factors as:
- the representative’s qualifications for the position or task at issue;
- whether the representative has personal or professional ties to the government or government officials;
- the number and reputation of the representative’s clientele and the representative’s reputation with the United States Embassy or Consulate, local bankers, clients, and other business associates; and
- the reasonableness of the proposed compensation for services rendered.
Consult your manager or the Compliance Officer if you are unsure about the appropriate due diligence procedure for your situation. As appropriate, based on the facts and circumstances of the engagement, we may require written agreements with each third party that includes a provision that the third party will comply with the FCPA and any other similar applicable law.
i. Red Flags. While conducting due diligence and throughout any subsequent relationship, you must monitor the individual or entity for any “red flags”. A “red flag” is a fact or circumstance that requires additional consideration and extra caution. Red flags may appear in many forms and can include, without limitation:
- payments in a country with a history or reputation for corruption or where a third party requests that a payment is made to a country or geographic location different from where the third party resides or conducts business;
- refusal to provide a certification of compliance with the FCPA, UKBA, or other applicable anti-corruption or anti-bribery law or regulation;
- unusual payment patterns or requests, including payments to unknown third parties, in cash, and payments made to bank accounts outside the country where the third part resides or does business;
- use of a shell or holding company that obscures ownership without credible explanation;
- a third party has a familial, personal or business relationship with the government or a government official;
- requests for payments “up front” or statements that a particular amount of money is needed to “get the approval,” “get the business,” “make the necessary arrangements” or similar expressions;
- a third party appears to lack qualifications or resources;
- requests that agreements or communications be kept secret (other than a customary nondisclosure or confidentiality agreement);
- a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
- a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
- you become aware that a third party engages in, or has been accused of engaging in, improper business practices (e.g., through credible rumors or media reports);
- you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;
- a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
- a third party requests that you provide employment or some other advantage to a friend or relative; and
- you or others at Evidation are offered unusually generous gifts or offered lavish hospitality by a third party.
You are responsible for monitoring your interactions and engagements with any representative, partner, consultant, distributor, agent, service provider, or other third party, including in any email and other communications and documents, for red flags. Any red flags should be brought promptly to the attention of your manager, the Compliance Officer, or reported to the Speak Up Hotline or the web or mobile site set forth in the Speak Up Policy, to determine appropriate handling and resolution of the red flags, which may include terminating any business relationship with the individual or entity or (if appropriate) reporting such individual or entities to the relevant authority. Failure to do so is considered a violation of this Policy and Evidation’s Code of Conduct, among other applicable policies.
F. Books and Records. We are legally required, and expect our employees, representatives, and service providers, to keep accurate and timely financial records and have appropriate internal controls in place to evidence the business reason for making payments to third parties, including any government officials, regardless of whether such payments occur directly or indirectly.
All Evidation employees, representatives, and service providers must maintain accurate records of all transactions and assist in ensuring that our books and records accurately and fairly reflect, with appropriate detail, all transactions, expenses or other dispositions of assets. To that end, you are prohibited from falsifying any business or accounting record and must truthfully report and record all dispositions of assets. Undisclosed or unrecorded funds or assets, for any purpose, are prohibited.
If you have any questions on how to record a transaction, or what other documentation may be needed to evidence a transaction or activity, refer the question to your manager or the Compliance Officer.
G. Internal Reporting. Compliance with this Policy is, first and foremost, the individual responsibility of every Evidation employee, representative, and service provider. We are committed to ensuring that any questions or concerns related to this Policy are addressed in a safe and confidential manner. Employees, representatives, and service providers are encouraged, and in some cases required, to follow the Speak Up Policy to submit any question, concern, or report of a suspected violation of law or this Policy. Any questions or reports will be addressed promptly and treated as confidential, as set forth in our Speak Up Policy. As set forth in Evidation’s Speak Up Policy, we will not allow any retaliation against any person who reports a matter in good faith and strives to keep complaints, internal reviews, and the terms of resolution (if any) confidential to the fullest extent practicable.
You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this Policy has occurred or may occur, you must notify the Compliance Officer, or report it in accordance with our Speak Up Policy as soon as possible.
IV. ENFORCEMENT OF THIS POLICY
Any employee, representative, or service provider found in violation of this Policy will be subject to disciplinary action, up to and including termination of employment or other relationship with Evidation. Third parties who violate this Policy may be subject to termination of all commercial relationships with Evidation. In addition, an individual engaging in any of the activities prohibited in this Policy may be subject to individual criminal or civil liability in accordance with applicable law or regulation. As needed, the Compliance Officer will consult with outside legal counsel, the Chairperson of the Audit Committee, and, if necessary, the full Board of Directors to conduct an investigation of any reported violation or suspected violation of law or this Policy, or to determine the appropriate resolution or mitigation of any violation.
As set forth in Evidation’s Code of Conduct, and other applicable company policies, all employees, representatives, and service providers are expected to cooperate with us, outside legal counsel, outside auditors, or other similar parties in any investigations and in identifying and implementing appropriate resolutions and mitigation measures. Failure to cooperate in an internal review or remedial measures will be treated as a breach of your obligations to us, will be dealt with in accordance with Evidation’s policies and applicable law, and may include disciplinary measures such as termination.
From time to time, Evidation employees, representatives, and service providers may be required to complete anti-corruption training and acknowledge commitment to, full understanding of, and compliance with this Policy. All such assigned training must be completed during the specified time period. Failure to complete any training on this Policy will be considered a breach of your obligations to us and will be dealt with in accordance with Evidation’s policies and applicable law.
V. POLICY ADMINISTRATION
The Compliance Officer is responsible for reviewing this Policy and confirming that the procedures contained in this Policy are in place. The Compliance Officer may amend this Policy and procedures associated with this Policy at any time at their discretion. As set forth in the Speak Up Policy, the Compliance Officer, or a designee, will make regular reports to the Audit Committee regarding compliance with this policy and any complaints or reports relating to this Policy (if any).
VI. ASSOCIATED MATERIALS
This Policy is intended to supplement and not to replace existing Company policies and procedures, as they may exist from time to time. These additional policies can be accessed through our intranet and include (without limitation) our:
- Code of Conduct
- Employee Handbook; and
- Speak Up Policy.
As we continue to expand into new geographies, we are adopting policies and procedures to help ensure that we always act as good corporate citizens, wherever our service providers may be located. In that regard, we have adopted the company-wide “Anti-Bribery and Corruption Policy” based on two laws:
- The first is called the Foreign Corrupt Practices Act (“FCPA”), which is a federal law that prohibits employees of all U.S. companies, wherever located, from engaging in bribery or other corruption.
- The second is the Bribery Act 2010 (“UKBA”), which is a UK law that prohibits anyone who is associated with a company doing business in the UK from engaging in corrupt business practice and bribery anywhere in the world.
Both the FCPA and the UKBA apply globally, and so all employees, representatives, and service providers, and all people who we use as agents and intermediaries, are required to comply with both laws, and any other similar laws as may apply in any place where we do business.
Each of you is responsible for reviewing Evidation’s Anti-Bribery and Corruption Policy, Code of Conduct and Speak Up Policy, and these FAQs. If you have any questions on these documents, please feel free to reach out to your manager, the Compliance Officer, or the Speak Up Hotline or web or mobile site set forth in the Speak Up Policy.
Frequently Asked Questions
What are the FCPA and UKBA and why do they matter?
The FCPA is a law that prohibits employees of U.S. companies, wherever located, from offering or paying money or gifts to non-U.S. government employees for the purpose of obtaining or retaining business or other benefits. The UKBA goes further than this to prohibit the giving or accepting of bribes or ‘facilitation payments’ by employees of any company doing business anywhere.
Both laws are intended to prevent companies and their employees, contractors, affiliates, etc., from using bribes or gifts to influence others, including government officials, to grant favors, award contracts, or provide other improper benefits.
Both the FCPA and UKBA apply no matter where in the world you are.
Who is considered a “government official” under the FCPA and UKBA?
Under these laws a “government official” includes any officer, employee or representative of a government or government entity, whether they are an employee or representative acting on behalf of a government or for an organization controlled by a government. This will include any customs and border patrol agents, employees of public institutions such as state owned or state-controlled companies, hospitals, universities, utilities and other entities owned or controlled by the government. A “government official” is also considered to extend to any family member or other representative of any of the above listed positions.
What types of payments or gifts are prohibited by the FCPA and UKBA?
The FCPA and UKBA are intended to prevent the use of bribery to influence decisions by government officials who may be in a position to award business or other competitive advantages. Government officials can be influenced in many different ways other than through cash payments. U.S. regulators have sued individuals or companies for violating the FCPA based on giving the following “things of value” either directly to a foreign government employee, or indirectly, for example, through a distributor or other third party who provides the “thing of value” to a foreign government employee: gifts such as cars, jewelry, or electronics; excessive travel and entertainment expenses; educational or executive training expenses; promises of future employment; shares or dividends of a company; and many others.
Note that facilitating payments made to customs or border patrol agents (for example, to move products to the front of a line or obtain any other advantage) are strictly prohibited, and neither we nor any of our contractors, agents, suppliers, or any other affiliates, may make any such payments. Please be sure to work with Evidation’s Legal Department to ensure that we obtain anti-bribery representations in all supplier contracts to the extent possible.
Can I offer to give a government official free services to persuade them to purchase additional services or provide us some other benefit?
No. The FCPA and UKBA and similar laws in most other countries significantly restrict the types of gifts that may be offered to government employees. Gifts must be of token value, reasonable and customary. Gifts may never be in cash and must be accurately described in company expense reports.
Travel and entertainment (which is addressed in more detail below) must be directly related to (i) the promotion, demonstration or explanation of products or services or (ii) to the execution or performance of a contract with a foreign government or agency. In any case, gifts may never be for the purpose of influencing a government official’s decision-making or to persuade a government official to misuse their position.
Any gifts, travel or entertainment given to a government official in excess of $100 must be reported to and approved in advance by the Compliance Officer.
Can I give a government employee a coupon or cash equivalent to enable them to travel to one of our offices?
No. Coupons, gift cards or other cash equivalents are strictly prohibited by the FCPA and UKBA. We will pay reasonable lodging and other travel expenses when: (i) the trip has been approved by us in advance; (ii) the expenses are reasonable, bona fide and fully documented; (iii) payment is made directly to the provider and not to the government official directly (i.e., no per diems); and (iv) the trip is in furtherance of the execution or performance of a contract.
How do I know if a utility or enterprise is “state owned” (i.e., a “government official” under the FCPA and UKBA)?
Although there is no strict definition, courts have identified the following as evidence that an entity is “state owned”:
- The foreign state’s characterization of the entity and its employees;
- The foreign state’s degree of control over the entity, e.g., whether it appoints key managers;
- The purpose of the entity’s activities, e.g., whether it provides services to all or nearly all inhabitants;
- The entity’s obligations and privileges under the foreign state’s law, including whether the entity exercises exclusive or controlling power to administer its designated functions;
- The circumstances surrounding the entity’s creation; and
- The foreign state’s extent of ownership of the entity, including the level of financial support by the state (e.g., subsidies, special tax treatment, and loans).
Can I hire agents to make a payment or gift to a government official on our behalf? Can I pay for the gift myself?
No. We can be liable for improper payments or gifts made by parties acting on our behalf if we had prior knowledge of or should reasonably have known about the payment or gift. We can also be liable for improper payments or gifts you make directly, and of course, you could be liable yourself for any improper payments or gifts you make on your own.
Am I subject to the FCPA and UKBA even if I’m not a citizen of the U.S. or a British Subject?
Yes. As an employee of a U.S. company, you must abide by the FCPA. Similarly, as an employee of a U.S. company that trades within the United Kingdom, you must also adhere to the UKBA.
What is a ‘facilitation payment’?
Facilitation payments are bribes and are therefore illegal. They differ from more conventional bribes in four ways, and so present different problems for companies both in identifying and avoiding them:
- A facilitation payment is usually made to ensure performance of a business or function that would often be considered routine in the United States or United Kingdom (for example, clearing you through passport control).
- When conducting business in some parts of the world the expectation of payments to facilitate routine action is common.
- The costs of not making a payment can be disproportionate to the potential losses suffered. The failure to pay a $10 facilitation payment to a customs official could result in a lengthy delay in getting goods into a country or simply clearing passport control.
- The consequences of non-payment of facilitation payments are not always purely economic. A customs official could demand a “fee” in order to allow someone to board an airplane or propose the matter be dealt with in the morning at the police station. In such a circumstance, an individual’s liberty or personal safety might be at risk by not making a facilitation payment.
What if I am being extorted for money, placed under duress, being threatened of being subject to intimidation?
If a payment is extorted, or if personal safety or protection of life is involved, and you are being compelled to pay, the payment constitutes extortion. Any payments extorted under such compulsion or duress should be reported immediately to the Compliance Officer as soon as it is safe for you to do so and then must be recorded appropriately in conjunction with the Evidation Legal Department.
Are there any gifts that are appropriate for government employees?
Small gifts, such as tote-bags with our logo, may be given on customary gift-giving occasions. Modest travel and entertainment expenses are also permissible if paid directly to the provider (e.g., travel agent). Gifts of cash or cash equivalents (e.g., coupons, gift cards) are never permissible. All gifts, travel and entertainment expenses must always be accurately and timely recorded in expense reports.
Someone has offered me a bribe or asked me to pay a bribe – what should I do?
If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery has or may occur, you must notify the Compliance Officer.
What should I do if I learn a fellow employee has paid a bribe or made a facilitation payment?
You are required to report, in person or in writing, any known or suspected bribes or facilitation payments made by anybody at Evidation or by any person or company associated with Evidation (no matter how senior or important you deem them to be) to the Compliance Officer.
You must report the activity or your suspicion as soon as you can.
You may report your concerns using our Speak Up Policy.
You will not be disadvantaged in any way for reporting any violation of the FCPA or UKBA or our Anti-Bribery and Corruption Policy.