Anti-Corruption Policy

Una Consulting does not take part in acts of corruption or pays bribes either directly or indirectly. Una Consulting prohibits its employees from engaging in any acts of corruption and paying bribes to or accepting bribes from public officials and/or private individuals.

Una Consulting employees must not offer to, or accept from, third parties gifts, rewards, hospitality, benefits or other incentives that could affect party’s impartiality, influence a business decision or lead to improper performance of a duty. They must not offer or accept cash donations. Una Consulting employees may offer and accept ‘reasonable’ and ‘proportionate’ gifts and benefits, such as dinner, theatre or sporting event tickets. In determining what is ‘reasonable’ and ‘proportionate’, the employees should consider a value of the gift or benefit as well as frequency with which the same or similar gift or benefit is offered. In all cases, they must ensure that the gift or benefit is:

  • Given as an expression of goodwill and not in expectation of a return favor;
  • Proportionate with generally-accepted standards for hospitality;
  • Provided openly and transparently and is of a nature that will not cause the embarrassment of Una Consulting Ltd. if publicly reported;
  • Value of a gift or benefit must be symbolic and effect thereof must be non-binding in any terms.

Una Consulting employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of Una Consulting. This includes: acting on any client information gained through their employment with Una Consulting for personal gain, passing such information to a third party or acting in any way that could be construed as insider trading. If there is a potential for conflict, the interests of Una Consulting must take priority. The employees must disclose any personal conflict of interest or perceived conflict of interest to the Director of Una Consulting.

All Una Consulting employees who are involved in engaging services of external consultants, suppliers or advisers are responsible to ensure that such individuals are aware of the Una Consulting’s anti-corruption policy at the outset of the business relation. Una Consulting expects them to abide by the principles set out in this policy when working on behalf of and for Una Consulting.

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