1. Purpose
The purpose of this policy is to establish DAAVIZ’s commitment to maintaining the highest level of integrity, transparency, and ethical conduct in all business operations. It outlines the standards, responsibilities, and procedures to ensure compliance with anti-bribery and anti-corruption (ABAC) laws in jurisdictions where DAAVIZ operates.
2. Scope
This policy applies to all employees, directors, officers, agents, contractors, consultants, and any third-party entities acting on behalf of DAAVIZ (collectively referred to as “Representatives”). This policy covers interactions with public officials, private sector business partners, and any other third parties.
3. Definitions
•Bribery: Offering, promising, giving, or receiving any item of value (including money, gifts, services, or favors) to improperly influence a decision or secure an unfair advantage.
•Corruption: Misuse of public office, power, or authority for private gain, including actions such as extortion, fraud, and embezzlement.
•Facilitation Payments: Small payments made to expedite routine governmental actions, such as obtaining permits or processing official documents, are prohibited under this policy, regardless of whether they are considered customary in certain jurisdictions.
4. Prohibited Conduct
4.1 Bribery and Corruption
No Representative of DAAVIZ shall directly or indirectly offer, promise, authorize, request, accept, or provide any bribe, kickback, or illicit payment, whether in the form of cash, gifts, entertainment, or anything else of value, in exchange for business favors or preferential treatment.
4.2 Third-Party Relationships
DAAVIZ prohibits bribery in all forms, whether involving public officials or private entities. Representatives must exercise appropriate due diligence when engaging third parties (such as agents, consultants, and suppliers) to ensure they are committed to anti-bribery principles.
4.3 Facilitation Payments
Facilitation payments—small unofficial payments to expedite routine tasks—are strictly prohibited, regardless of whether they are common practice in the relevant jurisdiction.
4.4 Gifts, Entertainment, and Hospitality
While DAAVIZ recognizes that exchanging modest gifts and hospitality is customary in many business cultures, any such exchange must be appropriate, lawful, and reasonable in value. Gifts or hospitality offered or accepted must never be intended to improperly influence business decisions or create an appearance of impropriety.
5. Compliance with Applicable Laws
This policy is designed to ensure compliance with relevant local and international anti-corruption laws, including:
•The Prevention of Corruption Act, 1988 (India)
•The UK Bribery Act, 2010
•The U.S. Foreign Corrupt Practices Act (FCPA), 1977
Representatives must be aware of and comply with these laws, as well as any other applicable anti-bribery laws in the countries where DAAVIZ operates.
6. Due Diligence and Risk Assessment
6.1 Risk Assessment
DAAVIZ regularly assesses the bribery and corruption risks associated with its business operations, particularly in high-risk jurisdictions or industries. Identified risks are mitigated through enhanced due diligence, tailored internal controls, and ongoing monitoring.
6.2 Third-Party Due Diligence
Before entering into any contract or business relationship with a third party, DAAVIZ performs due diligence to ensure that the third party adheres to anti-corruption principles. Contracts with third parties include provisions requiring compliance with this policy and relevant laws.
7. Responsibilities
7.1 Employees and Representatives
All Representatives of DAAVIZ are responsible for adhering to this policy. Any violations may result in disciplinary action, including termination of employment or contracts and potential legal consequences.
7.2 Managers
Managers are responsible for promoting a culture of ethical conduct and ensuring that their teams understand and comply with this policy. Managers must ensure that employees attend anti-bribery and anti-corruption training.
7.3 Compliance Officer
DAAVIZ has appointed a designated Compliance Officer responsible for implementing and overseeing this policy, conducting risk assessments, and ensuring the effectiveness of anti-bribery procedures.
8. Training and Communication
All Representatives are required to undergo periodic training on this policy to ensure understanding of anti-bribery laws, the company’s expectations, and potential risks. Training will be conducted regularly and whenever significant changes to the policy are made.
9. Reporting and Whistleblowing
9.1 Reporting Violations
If any employee or third party becomes aware of any actual or suspected violation of this policy, they are encouraged to report it immediately. Reports may be made confidentially and anonymously to [designated hotline/email].
9.2 Whistleblower Protections
DAAVIZ provides full protection to individuals who report bribery or corruption in good faith. Retaliation against whistleblowers will not be tolerated and is subject to disciplinary action.
10. Monitoring and Auditing
DAAVIZ regularly reviews its internal controls, risk management systems, and compliance measures to ensure ongoing effectiveness. External audits may be conducted to verify compliance with this policy and anti-bribery laws.
11. Disciplinary Actions
Any violations of this policy may result in disciplinary action, up to and including termination of employment or contracts. Violators may also face prosecution under applicable anti-bribery and anti-corruption laws.
12. Review and Amendments
This policy will be reviewed annually or more frequently as necessary to reflect changes in legal, regulatory, or operational requirements. Any amendments will be communicated to all Representatives and relevant stakeholders.