Anti-Bribery and Anti-Corruption Policy

July 2023

Introduction:

At Global Recruit Co (GRC), we are committed to conducting our business with the highest standards of integrity and ethics. Our Anti-Bribery and Anti-Corruption Policy reinforces our zero-tolerance approach towards bribery and corrupt practices in any form. This policy outlines our commitment to preventing bribery and corruption, whether involving public officials, private entities, clients, migrants, or any other individuals or organisations. We expect all employees, migrants, suppliers, employers and representatives to adhere to this policy to maintain our reputation for ethical conduct and compliance with applicable laws and regulations.

Policy Statement:

  1. Prohibition of Bribery and Corruption:
    • GRC strictly prohibits the offering, solicitation, acceptance, or facilitation of bribes or corrupt practices in any business activity.
    • We do not engage in any action that could be construed as an attempt to unduly influence or gain unfair advantage, either directly or indirectly.
  2. Applicability and Scope:
    • This policy applies to all employees, directors, officers, agents, consultants, and any other representatives of GRC, regardless of their position or location.
    • The policy extends to all interactions with employers (clients), migrants (candidates), public officials, private entities, or any other individuals or organisations.
  3. Gifts, Hospitality, and Entertainment:
    • We recognise that business-related gifts, hospitality, and entertainment are common practices. However, such gestures should be reasonable, transparent, and not intended to influence any business decision.
    • Employees must not offer or accept gifts, hospitality, or entertainment that could be perceived as influencing or compromising their impartiality or integrity.
  4. Due Diligence and Third-Party Interactions:
    • We conduct due diligence on clients, partners, agents, and other third parties with whom we collaborate to identify and prevent any association with entities or individuals involved in bribery or corruption.
    • We engage in business relationships only with those who uphold similar anti-bribery and anti-corruption standards.
  5. Record-Keeping and Transparency:
    • Accurate and transparent records of all transactions, including financial transactions, must be maintained.
    • Falsifying or altering records to conceal illegal or unethical activities is strictly prohibited.
  6. Training and Awareness:
    • GRC provides regular training and awareness programs to all employees to ensure they understand and comply with this policy.
    • Employees and all other stakeholders are encouraged to raise concerns or seek guidance regarding potential violations of this policy without fear of retaliation and can do so through “Confidentiality Corner – Whistleblower Reporting Portal” on the GRC website.
  7. Compliance and Reporting:
    • All employees and representatives are responsible for complying with this policy and reporting any suspected or actual instances of bribery or corruption.
    • Reports can be made through the “Confidentiality Corner – Whistleblower Reporting Portal” on the GRC website or directly to the designated Compliance Officer.

Conclusion:

The Anti-Bribery and Anti-Corruption Policy at GRC reflects our unwavering commitment to ethical business practices. We expect all employees and representatives to act with honesty, integrity, and transparency, refraining from engaging in any behavior that compromises the reputation and values of our company. By adhering to this policy, we reinforce our dedication to conducting business responsibly and creating a fair and trustworthy environment for our clients, migrants, and all stakeholders involved.

Compliance and Consequences:

Failure to comply with this Policy may result in disciplinary action, up to and including termination of employment or the termination of a business relationship with a supplier or business partner.

Review and Updates:

This Policy will be reviewed regularly to ensure its effectiveness and relevance. Any updates or changes to this policy will be communicated to all employees, suppliers, and relevant stakeholders.

Signed,

Claire Negus

Co-Founder & CEO

Global Recruit Co