Anti-Bribery and Corruption Policy
Rules for preventing bribery and corruption in Client Focus business.
1. Policy statement
Client Focus prohibits offering, promising, giving, requesting or accepting a bribe or anything of value to or from any government official, corporate representative or employee of any organization to improperly obtain or retain business or advantage.
2. Applicable laws
This policy addresses the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, the India Prevention of Corruption Act 1988 and local law where Client Focus operates.
3. Facilitation payments
Facilitation payments are prohibited.
4. Gifts, hospitality and travel
Gifts, hospitality and travel must be modest and within applicable limits, approved in advance by a Principal and recorded accurately. They must never be used to influence a decision.
5. Political and charitable contributions
No contribution may be made on behalf of Client Focus without a Principal's approval. Contributions must never be used to obtain an improper advantage.
6. Third parties and intermediaries
Third parties must undergo due diligence and accept contractual anti-bribery clauses. Client Focus does not engage agents to win business with clients.
7. Books and records
Record transactions completely and accurately. Do not create false or misleading entries.
8. Training and acknowledgment
All employees receive training and acknowledge this policy on joining and annually thereafter.
9. Reporting and non-retaliation
Report suspected violations to a Principal or to security@clientfocusllc.com. Retaliation for good faith reporting is prohibited.
10. Enforcement
Violations may result in disciplinary action up to termination and referral to authorities.
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