What Constitutes Bribery?

Bribery is the act of offering, giving, receiving, or soliciting any financial or non-financial advantage with the intention of inducing or rewarding improper performance of a duty. Bribery may take many forms, including:

• Offering or receiving bribes: This includes any undue payments, benefits, or incentives offered to influence a decision or gain an improper advantage.
• Facilitation payments: These are small, unofficial payments made to expedite routine services or approvals, which are strictly prohibited by Bamsh Digital Marketing.
• Kickbacks or under-the-table arrangements: Such informal agreements or payments that result in improper benefits are not tolerated under this policy.

Bamsh Digital Marketing prohibits any form of bribery, whether direct or indirect, in both the public and private sectors. Our commitment is to conduct business in a manner that is not only compliant with local laws but also aligned with our ethical standards.

Gifts and Hospitality

While small tokens of appreciation or modest hospitality may be acceptable in business, they should never influence or appear to influence business decisions. Bamsh Digital Marketing has strict guidelines on the giving and receiving of gifts and hospitality to ensure they do not create a conflict of interest or constitute bribery. Employees must:

• Report any gifts or hospitality exceeding a pre-determined value threshold to management.
• Refuse extravagant or inappropriate gifts or favours that could influence or be perceived to influence business outcomes.
• Avoid offering gifts that could be misconstrued as attempts to gain favour or special treatment.

Third-Party Due Diligence

Bamsh Digital Marketing works with a wide range of third-party vendors, partners, and consultants. To mitigate the risk of bribery and corruption through third parties, we perform comprehensive due diligence before engaging with any external parties. This due diligence process includes:

• Verifying the legitimacy, reputation, and ethical standards of third parties.
• Ensuring all third-party contracts include explicit anti-bribery and anti-corruption clauses.
• Regular monitoring of third-party relationships to ensure compliance with our policies and procedures.

We recognise that third parties can represent the company in ways that impact our reputation, so we take every precaution to ensure they adhere to the same ethical standards that Bamsh Digital Marketing upholds.

Employee Responsibilities

Every employee at Bamsh Digital Marketing has a role to play in preventing, detecting, and reporting bribery and corruption. To support this, we provide:

• Regular Training: Ongoing training sessions ensure that employees are aware of their responsibilities under this policy, can identify risks, and understand the reporting procedures. This includes real-world scenarios and best practices for handling potential bribery situations.
• Reporting Requirements: Employees are encouraged and required to report any suspicious activities or breaches of this policy through established channels, without fear of retaliation. Our confidential reporting system ensures that all reports are taken seriously and investigated thoroughly.
• Personal Accountability: Employees are personally accountable for their actions and are expected to uphold the company’s commitment to ethical conduct at all times.

Reporting and Whistleblowing

If any employee, partner, or third party suspects a breach of this policy, they are required to report the matter immediately. Bamsh Digital Marketing maintains a confidential whistleblowing mechanism that allows individuals to report concerns anonymously, protecting whistleblowers from any form of retaliation. All reports will be investigated swiftly and thoroughly by a designated compliance officer, and necessary actions will be taken based on the findings.

Penalties for Non-Compliance

Violations of this policy will not be tolerated. Any employee or third party found to be involved in bribery or corruption will face disciplinary action, which may include termination of employment or contractual agreement. In addition to internal disciplinary measures, Bamsh Digital Marketing may pursue legal action where breaches involve criminal conduct. Non-compliance could also result in substantial reputational damage, legal penalties, and loss of business opportunities.

Monitoring, Auditing, and Review

Bamsh Digital Marketing will regularly monitor compliance with this policy through audits, risk assessments, and ongoing evaluations. Periodic assessments of our business processes, financial transactions, and third-party engagements are conducted to identify and address any areas of vulnerability. This policy will be reviewed annually and updated to reflect changes in legislation, industry best practices, and business operations.

Commitment from Leadership

Our leadership team at Bamsh Digital Marketing is fully committed to the principles outlined in this Anti-Bribery and Anti-Corruption Policy. We lead by example, promoting a culture of integrity and ethical behaviour across the company. By setting a strong tone from the top, we ensure that our commitment to preventing bribery and corruption is reinforced at every level of the organisation.