Anti-Bribery and Anti-Corruption Policy
Version 1.0 date ‘09’ November 2024
This Anti-Bribery and Anti-Corruption Policy (the “Policy”) was approved by Teto Finance Inc., a company duly incorporated in Canada, British Columbia, Incorporation number: BC1406818, registered office: 5811 Cooney Road, Suite 305, South Tower, Richmond BC V6X 3M1, Canada (“we”, “us”, “our”, “Company”), for the purpose to timely prevent and reveal bribery and corruption risks.
If you use our Services, you acknowledge that you have read and understood all of the terms and conditions of the Policy.
This Policy is governed, construed, interpreted, and enforced in accordance with the laws of Canada.
We reserve the right to change, vary, and revise this Policy. Unless clearly specified differently, such revised or updated versions will take effect as of the publishing date.
1. DEFINITIONS
In this Policy the following terms have the following definitions:
Anything of Value means any material benefit and should be interpreted broadly, and examples include:
a) loans, gifts and favours, cash or equivalent payments;
b) jobs or consulting arrangements;
c) donations to preferred political or charitable causes;
d) benefits of any kind granted to related third parties; and
e) entertainment and other forms of non-cash incentives
Bribe means an act of giving, offering or promising to provide, whether directly or indirectly, Anything of Value, to a person (whether a Public official or in the private sector) with the intent to obtain benefits, or retain business, or secure a business, or other advantages.
Facilitation Payment means “grease payments,” these are typically small, unofficial payments made directly to a Public official in their personal capacity. The purpose of such payments is to expedite or secure routine, non-discretionary government actions, such as accelerating customs clearance.
Kickback means the concealed or non-transparent provision of compensation to an agent, such as an employee or consultant, of another contracting party.
Public official means:
(a) a person who holds a legislative, administrative or judicial position of a state or any subdivision of a state; and
(b) a person who performs public duties or functions, paid or unpaid, for any state or a subdivision of a state, including a person employed by a board, commission, corporation, company or other body or authority that is established to perform a duty or function on behalf of a state or any subdivision of a state, or is performing such a duty or function; and
(c) an official or agent of a public international organization that is formed by two or more states or governments, or by two or more such public international organizations, and
(d) a political party, an official of a political party, or a candidate for political office; and
(e) other categories falling under the personal public official, according to the legislation.
2. GENERAL PROVISIONS
A variety of laws prohibit bribery and corruption in connection with the Company’s business activities, including dealings with Public officials, government entities, and private individuals, entities.
The Company has a zero-tolerance approach to bribery and corruption in all aspects of its operations. Engaging in bribery is not only illegal but also detrimental to our business.
The Company has developed proper internal processes to implement adequate and comprehensive anti-bribery and anti-corruption best practices.
The Company’s staff is properly trained and supported, to be compliant with the anti-bribery and anti-corruption processes of the Company.
3. PROHIBITION OF ILLEGAL PAYMENTS
Neither the Company, nor the Company’s personnel, are engaged and must not engage in any promise, authorization, offer, or providing Anything of Value under any circumstances, to or from any individual, whether in the public or private sector, directly or through an intermediary, with the intent to secure an improper purpose or advantage related to the Company’s business operations.
Although all forms of bribery and corruption are strictly forbidden under this Policy, acts of bribery involving Public officials are particularly severe and damaging. Therefore, the specific rules apply for interactions with Public officials, and extreme caution is exercised in all dealings with them.
The Company’s personnel are strictly prohibited to, directly or indirectly, request or accept a Bribe, as well as offer, pay or accept Bribes, Kickbacks.
It is also prohibited to pay Facilitation Payments by the Company, its personnel in any form, if officially and legally they are not fixed by the proper authorities.
The Company acknowledges that certain jurisdictions pose higher risks related to Bribes, Kickbacks, and Facilitation Payments. While protection against bribery and corruption is essential, enhanced assessment is carried out for transactions involving jurisdictions known for widespread corruption, past incidents of bribery violations, significant government involvement in the local economy, or prevalent state ownership.
4. HANDLING WITH HIGHER RISK COUNTERPARTIES
The Company engages with various counterparties, including clients, contractors, and intermediaries. To manage and mitigate bribery and corruption risks, the Company employs a risk-based approach to background screening and due diligence. The extent of due diligence is proportional to the counterparty’s risk level.
Common factors that elevate risk include:
(a) The jurisdiction’s inherent risk where the counterparty is based;
(b) Affiliations with countries subject to economic sanctions;
(c) Counterparties that are government-owned entities or are required to interact with Public officials on behalf of the Company;
(d) High-value transactions or business relationships;
(e) Associations with Public officials, their family members, or close associates.
The Company’s personnel are duly trained for identifying higher risk counterparties and ensuring appropriate due diligence, including adherence to Company rules.
When dealing with higher risks counterparties, the Company implements enhanced due diligence, could insert into the agreements proper anti-bribery and anticorruption clauses, clauses on implementation of ethical business practices, could require justification of commercial necessities etc.
5. GIFTS
The Company values building long-term relationships grounded in trust and mutual respect. Providing reasonable and proportionate gifts is recognized as a legitimate way to promote these objectives.
Small, branded items (e.g., pens, caps) or hospitality and entertainment related to business meetings or events may be offered or received on behalf of the Company, provided they are infrequent, they are of nominal value (not exceeding the amount fixed by the Company), they are offered transparently, they comply with local laws.
Gifts, hospitality, and entertainment must never be intended to influence, or appear to influence, the business decisions or actions of the recipient. They must not create a sense of obligation.
6. REPORTING LINES
If you have any requests or complaints you faced on or heard, related to the corruption or bribery risks, please contact us: Email: [email protected].
We draw your attention, that the Company has implemented whistleblowing practices, where personnel member is required to promptly report any suspected issues related to Bribes, Kickbacks, Facilitation payments etc.
In cases prescribed by the law, the Company may submit proper reports and notices to governmental authorities, police, courts
