Last Updated: December 9, 2024
1. INTRODUCTION
Aegis Vault Ltd. (“Company,” “we,” “our,” or “us”), a company incorporated under the laws of the British Virgin Islands with registration number 2163500, is committed to conducting business ethically and in compliance with all applicable anti-bribery and anti-corruption laws. This Anti-Bribery and Corruption Policy (“Policy”) outlines our zero-tolerance stance towards any form of bribery or corruption, ensuring that our operations remain transparent and uphold the highest standards of integrity.
2. DEFINITION OF BRIBERY AND CORRUPTION
2.1 Bribery
Offering, giving, receiving, or soliciting anything of value as a means of influencing the actions of an individual or organization.
2.2 Corruption
Abuse of power for private gain, which includes unethical behavior such as bribery, extortion, or embezzlement.
We strictly prohibit all forms of bribery and corruption, whether direct or indirect, in connection with our business activities.
3. PROHIBITED CONDUCT
3.1 Bribery and Facilitation Payments
We do not tolerate:
- Bribery of any kind, including offering or accepting money, gifts, favors, or other incentives to gain an improper advantage
- Facilitation Payments, which are small payments made to expedite routine governmental actions
- Any attempt to circumvent these prohibitions through third parties
3.2 Gifts and Hospitality
- Normal business hospitality must be reasonable and proportionate
- Any gift or hospitality must not be intended to influence decisions improperly
- Excessive gifts or entertainment will be considered potential bribes
- All gifts must be recorded in the Company’s gift register
4. RESPONSIBILITIES
4.1 Company Personnel
All employees, directors, officers, agents, and representatives must:
- Avoid any actions that could be perceived as bribery or corruption
- Report suspected violations promptly
- Maintain accurate records of all transactions
- Complete required anti-bribery training
4.2 Third Parties
All third parties working with the Company must:
- Comply with this Policy
- Undergo appropriate due diligence
- Maintain transparent business practices
5. REPORTING AND WHISTLEBLOWING
5.1 Reporting Channels
Reports can be made through:
- Email: [email protected]
- Written report to the Compliance Officer
- Anonymous whistleblowing channel
5.2 Protection
We ensure:
- Confidentiality of reports
- Protection against retaliation
- Fair investigation of all reports
- Appropriate follow-up actions
6. RECORD KEEPING
The Company maintains:
- Accurate financial records
- Detailed gift and hospitality registers
- Due diligence documentation
- Training records
- Investigation reports
7. TRAINING AND COMPLIANCE
7.1 Training
We provide:
- Regular anti-bribery training
- Updates on regulatory changes
- Practical guidance on compliance
- Risk assessment training
7.2 Compliance Monitoring
We conduct:
- Regular risk assessments
- Internal audits
- Compliance reviews
- Third-party due diligence
8. CONSEQUENCES OF NON-COMPLIANCE
8.1 Internal Consequences
Violations may result in:
- Disciplinary action
- Termination of employment
- Legal action for damages
- Reporting to authorities
8.2 Legal Consequences
Individuals may face:
- Criminal prosecution
- Civil penalties
- Regulatory sanctions
- Professional disbarment
9. POLICY UPDATES
- This Policy is reviewed annually
- Updates reflect regulatory changes
- All changes are communicated promptly
- Compliance is mandatory for all personnel
10. JURISDICTION
This Policy is governed by the laws of the British Virgin Islands and complies with:
- BVI Anti-Money Laundering Regulations
- UK Bribery Act 2010
- FCPA requirements
- International anti-corruption standards