Objective, Scope, Definitions and Key Principles


This document sets out the policy of FTPL on combating corruption and to conduct business in an honest and ethical manner. FTPL takes a zero-tolerance approach to bribery and corruption and is committed to act professionally, fairly, and with integrity in all our dealings wherever it operates. FTPL is committed to implement and enforce effective systems to counter bribery. This document sets out the Company’s policy on bribery and other forms of unlawful payments.


This Policy shall apply to all staff including directors, Key Management Personnel (“KMP”), employees and all appointed third-party representatives of the Company such as agents, consultants, and others working on behalf of the Company irrespective of their location or function.


“Bribery” is the “offer of undue reward by or to any person in a public sector, private employee, colleague or representative of another organisation in order to influence his / her behavior in office and to induce them to act in contravention of the rules and regulations, ethics, trust, and integrity”.

“Corruption” is the “abuse of entrusted power for private gain”.

Key Principles

FTPL employees and third-party service providers are prohibited from:

  • Offering or suggesting a Bribe, or authorizing the offer or suggestion of a Bribe
  • Paying Bribes
  • Soliciting or accepting a Bribe to influence a decision, to obtain unauthorized access to confidential information, or to commit or omit to do an act, whether or not the outcome would have been the same without the Bribe
  • Making facilitation (unofficial payments to speed up the administrative process) payments
  • Using another party to conduct any of the above
  • Using vendors or suppliers that do not have high standards on bribery and corruption
  • Processing funds are known to be, or reasonably suspected of being, the proceeds of bribery or corruption.

Fee Payment

Where an agent or intermediary is used to make introductions to officials of public or government bodies and agencies, steps must be taken to ensure that any fee paid by FTPL is proportionate to the activity being performed and in accordance with local law and the requirements of this anti-corruption policy.

No such fee payments can be made without the express approval of business line management who may obtain advice from Compliance or, if necessary.

Charitable Donations

When funds are donated in FTPL’s name for charitable purposes, appropriate due diligence must be conducted to ensure that, where a public official or public body is associated with the charity, a written agreement is obtained.

Any charitable donation must always be made directly to a recognized charitable organisation and not via another party or individual. In case of doubt refer to line management who may obtain advice from the Compliance Officer / CEO.

Political Donations

No political contribution to a candidate for public office, an elected official, a political party or political action committee, can be made, on behalf of FTPL without prior approval from the Compliance Officer / CEO.

Offers of employment

Care must be taken when providing work experience or employment to people that are connected to, or are relatives of, senior public officials. Although it is not prohibited to employ such staff it is important to avoid any perception that any hiring is for an improper purpose. Where such hiring is being considered, approval from business line management must be obtained.

Gifts and entertainment

Meals, entertainment, and gifts to Government Officials and Private Parties may be permissible in certain circumstances if there are reasonable and appropriate in light of the local law, custom, and practice, not excessive in nature or frequency, and not offered or given for an improper purpose. Pre-clearance must be obtained from the Compliance Officer / CEO for any of the above expenditure.

Employees and persons associated with the Company may not offer gifts and hospitality from any party.


  • Compliance Officer shall undertake a periodic review and update this policy to reflect applicable law(s) and /or latest notifications released by the regulating authorities from time to time.
  • Compliance Officer shall monitor the effectiveness and review the implementation of the compliance principles set forth in this Policy, regularly considering its suitability, adequacy, and effectiveness.
  • Any violation of this policy may have significant consequences, including potential prosecution, fines and other penalties for improper conduct, as well as disciplinary action up to and including termination of the concerned.
  • Vendor/Employee should cooperate with any internal audits/investigations conducted by FTPL and provide information in a timely manner.