Anti-bribery & Anti-corruption

FriendLoan takes a zero-tolerance approach to bribery and corruption and is committed to act professionally, fairly, and with integrity in all dealings.

Objective, Scope, Definitions and Key Principles

Objective

This document sets out the policy of FTPL on combating corruption and conducting 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 dealings.

Scope

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

Definitions

  • 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 behavior and induce them to act in contravention of rules, 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
  • Paying Bribes
  • Soliciting or accepting a Bribe
  • Making facilitation payments
  • Using another party to conduct any of the above
  • Using vendors or suppliers without high standards on bribery and corruption
  • Processing funds known or suspected to be proceeds of bribery or corruption

Fee Payment

Where agents or intermediaries are used, steps must be taken to ensure fees are proportionate and in accordance with local law. No fee payments without express approval of business line management.

Charitable Donations

Appropriate due diligence required. Donations must be made directly to recognized charitable organisations. Refer to Compliance Officer / CEO in case of doubt.

Political Donations

No political contributions without prior approval from Compliance Officer / CEO.

Offers of Employment

Care must be taken when providing employment to people connected to senior public officials. Approval from business line management required.

Gifts and Entertainment

May be permissible if reasonable, appropriate under local law, not excessive, and not for improper purpose. Pre-clearance required from Compliance Officer / CEO.

Governance

  • Compliance Officer undertakes periodic review of this policy
  • Monitors effectiveness and implementation
  • Violations may result in prosecution, fines, disciplinary action up to termination
  • Vendors/Employees must cooperate with internal audits/investigations