Our commitment
Unhectic Limited has zero tolerance for bribery and corruption. We comply with the UK Bribery Act 2010 in all jurisdictions where we operate, including the United Kingdom and India, and we apply the same standard to every part of our business regardless of where the work happens or who the counterparty is. Our commercial success is built on the quality of the work we do, not on improper inducements, favours, or shortcuts. We would rather lose business than win it on the wrong terms.
Scope
This statement applies to all directors, employees, contractors, and agents of Unhectic Limited. It also applies to our suppliers and sub-contractors when they are acting on our behalf in connection with our business. Anyone who acts in our name is expected to read this statement, understand it, and operate consistently with it. Where a supplier’s own anti-bribery position falls short of ours, we apply ours.
What is prohibited
Bribery
Offering, giving, receiving, or soliciting any financial or other advantage with the intention of inducing the improper performance of a function or activity is prohibited. This applies in any direction — from us to a counterparty, or from a counterparty to us — and to private commercial counterparties as well as public officials. Bribery of foreign public officials is specifically prohibited under the UK Bribery Act 2010 and is treated equivalently in our internal practice.
Kickbacks
No employee, agent, or representative of Unhectic Limited is permitted to give or accept any payment, gift, service, or other advantage in connection with the awarding of business, the selection of a supplier, or the placement of an order. Commission and referral arrangements are only acceptable where they are documented in a written agreement, disclosed to all relevant parties, and consistent with this statement.
Facilitation payments
No facilitation payments — small unofficial payments made to expedite routine government services such as permits, customs clearance, or visas — are permitted in any jurisdiction in which we operate. Even where local custom may suggest such payments are normal, our policy is no. If you find yourself being asked for one, decline politely, document the request, and report it to a director without delay.
Gifts and hospitality
Modest, occasional, transparent gifts and hospitality of clear business purpose are acceptable. A working lunch, a trade-conference dinner, or a small seasonal token of thanks would normally fall within this. Anything that could create an obligation, influence a commercial decision, or appear improper to an outside observer is not. When in doubt, decline.
As a practical guide, any material gift or hospitality — we treat “material” as anything with a value above £100 — must be disclosed to and approved by a director before it is given or accepted. Recurring or sequenced gifts that aggregate to more than this threshold are treated as material in the aggregate. Cash or cash-equivalents (including gift cards) are not acceptable in any amount.
Reporting concerns
Anyone who has concerns about a possible breach of this statement — whether they have witnessed it, suspect it, or have been asked to participate — may raise those concerns in confidence to [email protected]. Concerns may be raised anonymously. We do not retaliate against anyone who raises a concern in good faith, even if the concern turns out to be mistaken. Suppressing or attempting to discourage a good-faith report is itself a breach of this statement.
Training and awareness
All directors and employees receive anti-bribery training on joining Unhectic Limited and at least annually thereafter. Training covers the principles in this statement, the requirements of the UK Bribery Act 2010, the practical scenarios most likely to arise in our work, and the channels available to raise concerns. Suppliers and sub-contractors that work on our behalf are expected to maintain equivalent standards within their own organisations.
Annual review
This statement is reviewed at least annually by a director, and earlier if our practice or applicable law changes materially. The version banner at the top of this page reflects the current version. Where we make material changes, we surface them via the version banner so that anyone relying on the statement can see what has moved.