It is our policy to conduct all of our business in an honest and ethical manner. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and implementing and enforcing effective systems to counter bribery.
We are committed to complying with all relevant anti-corruption laws and have implemented a system of anti-corruption measures including:
- Training Staff: training will be provided to all directors, officers and employees on the anti-corruption policies and procedures.
- Risk Assessment: thorough reviews based on corruption risk assessments will be conducted.
- Monitoring and Review: policies and procedures will be reviewed regularly to reflect changes in law and business practice, and in accordance with the findings of regular risk assessments.
Our anti-corruption policy applies to all directors, officers and employees of the Company. In addition, all third parties with whom we have dealings with will be encouraged or, in some instances, required to meet similarly high anti-corruption standards.
As per the Anti-corruption Policy
Scope and applicability
As per the Anti-corruption Policy.
What constitutes bribe?
A bribe is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe. It is also a separate offence to bribe a government/ public official.
A bribe may be anything of value and not just money — gifts, inside information, or other favors, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function – and can pass directly or through a third party.
Gifts and hospitality
Employees or members of their immediate families (spouse, mother, father, son, daughter, brother, sister or any of these step- or in-law relationships) should not provide, solicit or accept cash or its equivalent, entertainment, favors, gifts or anything of substance to or from competitors, vendors, suppliers, customers or others that do business or are trying to do business with Inspira. All relationships with those who Inspira deals with should be cordial, but must be on an arm’s length basis. Nothing should be accepted, nor should the employee have any outside involvement, that could impair, or give the appearance of impairing, an employee’s ability to perform his/her duties or to exercise business judgment in a fair and unbiased manner.
This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure, such as calendars, diaries, pens, meals and invitations to theatre and sporting events (given and received), to or from third parties. However, the key determining factor for appropriateness of the gift or hospitality and/or its value would be based on facts and circumstances under which such gift or hospitality is provided.
To avoid committing a bribery offence, the gift or hospitality must be:
- a. Reasonable and justifiable in all the circumstances
- b. Intended to improve the image of Inspira, better present its products and services or establish cordial relations
The giving or receiving gifts or hospitality is acceptable under this Policy if the following requirements are met:
Examples of Token Gifts:
- • It is not made with the intention of influencing a third party to obtain/ retain business or a business advantage or to reward the provision or retention of business or a business advantage or in explicit or implicit exchange for favors/ benefits or for any other corrupt purpose.
- • It complies with local laws and customs.
- • It is appropriate in the circumstances. For example, in U.S. it is customary for small gifts to be given at Christmas times.
- • Taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time.
- • It is given openly, not secretly and in a manner that avoids the appearance of impropriety.
Corporate calendar, pens, mugs, books, T-shirts, wine bottles, bouquet of flowers or a pack of sweets or dry fruits.
What is not acceptable?
It is not acceptable for any employee of Inspira (or someone on his / her behalf) to:
- • Accept an offer of a gift of any size from any third party which is in negotiation with, or is submitting a proposal with Inspira.
- • Give, promise to give or offer, any payment, gift, hospitality or advantage with the expectation or hope that a business advantage will be given or received or to reward a business advantage already given.
- • Give, promise to give or offer, any payment, gift or hospitality to a government official, agent co-representative to “facilitate” or expedite a routine procedure.
- • Accept or solicit any payment, advantage, gift or hospitality from a third party that you know or suspect is being offered with the expectation that it will obtain a business advantage for them.
- • Threaten or retaliate against, another employee who has refused to commit a bribery offence or who has raised concerns under this Policy.
- • Engage in any activity that might lead to a breach of this Policy.
The points stated above are illustrative in nature and in no way intend to limit the applicability of this Policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for Inspira. Employees are required to avoid any activity that might lead to or suggest a breach of this Policy.
Employees must notify his / her Manager as soon as possible if you believe or suspect that a breach of or conflict with this Policy has occurred or may occur in the future.
Any employee who breaches this Policy will face disciplinary action, which could result in dismissal. We reserve our right to terminate our contractual relationship with you if you breach this Policy. Any breach of this Policy would also result in imposition of large fines/ imprisonment on the individual/ the Company as the case may be or termination of contract with a third party.
Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness.
What are the governing legislations?
All national laws relating to bribery and corruption, especially such laws that are in place in jurisdictions where Inspira has an office(s) or carries out its work, are of importance to the Company. In setting out the principles included in this Policy particular attention has been paid to the requirements of:
- Anti -corruption Legislations in India
- The UK Bribery Act 2010.
- The Foreign and Corrupt Practices Act 1977 (“FCPA”).
How to raise a concern?
Every person, to whom this policy applies too, is encouraged to raise their concerns about any bribery issue or suspicion of malpractice at the earliest possible stage. If he / she is unsure whether a particular act constitutes bribery or corruption or if he / she has any other queries, these should be raised with their respective Manager.
It is his / her responsibility to inform / report it to their respective Managers as soon as possible if you are offered a bribe by a third party, you are asked to make one, suspect that this may happen in the future or believe that you are a victim of another form of corruption or other unlawful activity. You must refuse to accept or make the payment from or to a third party, explain our policy against accepting or making such payment and make it clear that the refusal is final and non- negotiable because of this Policy. If you encounter any difficulty making this refusal, you should seek assistance from your Manager.
Who is responsible for the Policy and Training?
The Board of Directors has overall responsibility for ensuring that this Policy complies with our legal and ethical obligations and that all those under our control comply with it. Reinforce anti-corruption policies and procedures we provide training to our employees at the time of Induction and at regular intervals and in a way have created a buzz in the workplace about the importance of individual responsibility for acting in accordance with anti-corruption laws including FCPA.
Managers at all levels are responsible for ensuring that those reporting to them are made aware of and understand this Policy, undertake training on how to implement and adhere to it and also monitor compliance of it.
Waiver and amendment of the policy
We are committed to continuously reviewing and updating our policies and procedures based on the learning. We will monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Therefore, this document is subject to modification. Any amendment or waiver of any provision of this Policy must be approved in writing by the Company’s Board of Directors.