For All Colleagues, Contractors, Suppliers and Distributors

 

1. Purpose

This policy ensures that:

• INNOVEL LTD and all individuals acting on its behalf comply with applicable global anti-bribery and corruption laws, including (but not limited to) the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and relevant local legislation in the countries where we operate.

• Our business is conducted in accordance with the highest ethical standards and the values to which we hold ourselves accountable.

• Risks related to bribery and corruption are proactively identified, prevented, and reported.

2. Definitions

 

Bribery:
Offering, promising, giving, requesting, agreeing to receive or accepting money or anything of value with the intention of improperly influencing a decision or securing an improper advantage.
Examples include (but are not limited to):

• Gifts, including cash or cash equivalents (e.g., gift cards).

• Favourable contract terms.

• Hospitality such as meals, accommodation, travel, or invitations to cultural or sporting events.

• Promotional or business-related expenses, including travel and accommodation.

• Favours of value (e.g., employment opportunities for an individual or their relative).

• Free use of company facilities, property or services.

• Political donations.

• Charitable donations made with the intention of influencing a decision.

 

Corruption:
The abuse or misuse of entrusted power for private gain.
Examples include fraud, bribery, extortion, embezzlement and facilitation payments.

 

Facilitation Payments:
Small, unofficial payments made to expedite or secure routine governmental actions (e.g., issuing permits, arranging inspections, releasing goods from customs).

These are prohibited even where they are considered customary.

3. Policy Requirements

​

• INNOVEL LTD has zero tolerance for bribery and corruption in any form.

• You must not offer, request, give or accept bribes, whether involving public officials or private individuals.

• You must not use third parties (agents, consultants, intermediaries or suppliers) to engage in bribery on INNOVEL LTD’s behalf.

• All third parties acting for or representing INNOVEL LTD must be made aware of our zero-tolerance approach and must adhere to equivalent standards. (Refer to the Third-Party Intermediary Procedure.)

• Facilitation payments are strictly prohibited, regardless of local customs or pressures.

• Political donations using INNOVEL LTD funds are prohibited unless expressly approved in writing and in advance by the CEO.

• All gifts and hospitality given or received must comply with this policy and must never influence, or appear to influence, a business decision.

• You are required to report immediately any suspected or actual bribery, corruption, or policy breach to management or via the designated reporting channel.

• INNOVEL LTD will protect individuals who report concerns in good faith from retaliation.

​

4. Exceptions: Immediate Threat to Safety

A payment that would otherwise breach this policy may be made only in exceptional circumstances where you, or another INNOVEL LTD representative, face a genuine and imminent threat to life, personal safety or well-being.
Any such incident must be reported as soon as safely possible.

 

Consequences of Breach:

Breaching this policy may result in:

• Disciplinary action, up to and including termination of employment or contract.

• Reporting to regulatory or law-enforcement authorities.

• Personal criminal liability under applicable anti-bribery legislation.

​

5. Appendix

 

5.1 Document Responsibilities

​

Approver - CEO - Stewart Munro

Owner - CEO - Stewart Munro

Writer - Operations Manager - Claudia Mallon

​

​