Corporate Governance

Anti-Bribery & Corruption Policy

Integrity is fundamental to trusted business relationships. Aqitas is committed to conducting business honestly, transparently and in accordance with applicable anti-bribery and anti-corruption laws.

We do not offer, request, authorise or accept bribes or other improper advantages in any form. Our objective is to build long-term relationships based on trust, fairness and ethical conduct.

01 / Our commitment

Ethical business starts with integrity.

Aqitas believes commercial success should never come at the expense of ethical behaviour.

Every business decision should be capable of withstanding appropriate scrutiny. We expect anyone acting on behalf of Aqitas to conduct themselves honestly, avoid conflicts of interest where possible and comply with applicable laws and regulations.

Bribery and corruption undermine confidence, distort fair competition and expose organisations to significant legal and reputational risk. We are committed to helping prevent those risks through responsible business practices.

02 / What we mean by bribery

Understanding improper influence

Bribery involves offering, promising, giving, requesting or accepting something of value in order to improperly influence a business decision or secure an unfair advantage.

  • Cash payments or cash equivalents
  • Gifts intended to improperly influence a decision
  • Excessive hospitality or entertainment
  • Kickbacks or secret commissions
  • Improper facilitation payments
  • Favourable treatment in exchange for personal benefit
  • Undisclosed personal incentives

Whether something constitutes bribery depends on the circumstances, applicable law and intent.

03 / Our principles

The standards that guide our conduct

01

Integrity

We act honestly and seek to make decisions that are objective, transparent and justifiable.

02

Transparency

Business relationships, commercial decisions and financial arrangements should be appropriately documented and capable of review.

03

Accountability

Important decisions should have clear ownership, supporting evidence and appropriate oversight.

04

Fair Competition

We compete fairly and do not seek commercial advantage through improper payments or unethical conduct.

04 / Gifts, hospitality & business courtesies

Building relationships responsibly

Reasonable business hospitality can help develop professional relationships. However, gifts, hospitality or entertainment must never be used to influence, or appear to influence, business decisions.

Gift OfferedStart
Reasonable?Check
Transparent?Evidence
Appropriate?Review
Document if necessaryRecord
ProceedApproved
If any answer is noReview Required
05 / Third parties

Working with integrity throughout our relationships

Aqitas recognises that corruption risks may arise through third parties such as suppliers, contractors, consultants and business partners.

01Supplier
02Due Diligence
03Evidence
04Risk Review
05Approval
06Monitoring

Where appropriate, we seek to understand who we work with and encourage responsible business conduct throughout our commercial relationships. This may include proportionate due diligence, contractual expectations and ongoing review where appropriate.

06 / Conflicts of interest

Decisions should be objective.

Personal interests should not improperly influence professional judgement. Potential conflicts of interest should be disclosed as early as reasonably possible so that they can be assessed and managed appropriately.

  • Financial interests
  • Close personal relationships
  • Outside employment
  • Family connections
  • Personal investments
  • Gifts that could affect impartiality
07 / Speaking up

Concerns should be raised.

Anyone who becomes aware of behaviour that may involve bribery, corruption or other unethical conduct is encouraged to raise the concern promptly.

Concerns should be considered respectfully and objectively. Aqitas does not support retaliation against individuals who raise genuine concerns in good faith.

08 / Governance

Responsible oversight

As Aqitas grows, we intend to continue developing our governance framework, policies and internal controls to support ethical business conduct.

Responsible governance is an ongoing process rather than a one-time exercise.

09 / Review

Continuous improvement

This policy will be reviewed periodically to ensure it remains appropriate for the organisation, reflects applicable legal requirements and supports responsible business practices.

Policy Owner
Aqitas
Review Frequency
Periodic
Version
1.0
Status
Active
10 / Contact

Questions about this policy?

If you have questions regarding this policy or wish to raise a concern relating to business conduct, please contact Aqitas through our Contact page.

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