Anti-Bribery and Anti-Corruption Policy

Sysvine Technologies is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. Its policy is to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, wherever it operates, of not engaging in bribery or corruption.

This Anti-bribery and Anti-corruption Policy applies to all individuals in Sysvine. We believe 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. “Government/ public official” includes officials, whether elected or appointed, who hold a legislative, administrative or judicial position of any kind in a country or territory.

The Chief Executive Officer 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.

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. We explain this policy to new joinees as part of their induction and orientation to Sysvine.

The Compliance and HR team are responsible for this Policy and for monitoring its use and effectiveness (and dealing with any queries on its interpretation). Management at all levels is responsible for ensuring that those reporting to them are made aware of and understand this Policy and attend regular training on how to implement and adhere to it.

Every person to whom this policy applies is responsible for the success of this Policy and should ensure that he / she should use it to disclose any suspected activity or wrong-doing.

We are committed to continuously reviewing and updating our policies and procedures based on the learning. This is so even when Sysvine enters new market/ sector/ country which may pose a risk under this Policy. The Compliance and HR team will monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness. The Policy will be reviewed and audited from time to time and amendments made to this policy when needed.