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ANTI-CORRUPTION POLICY

Sentient Concepts is committed to conducting its business with the highest standards of ethics and integrity. This Anti-Corruption Policy outlines our firm stance against any form of corruption and bribery, both domestically and internationally. We strictly prohibit any activities that may compromise the integrity of our organization, our employees, or our business partners.

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Definitions

1. Corruption: Corruption refers to any act of bribery, embezzlement, fraud, extortion, money laundering, or other illegal or unethical practices that seek to gain an unfair advantage or benefit at the expense of others.

2. Bribery: Bribery includes the offering, giving, receiving, or soliciting of anything of value, directly or indirectly, to influence or reward the actions of individuals in a position of trust or authority, whether in the public or private sector.

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Compliance with Laws

Sentient Concepts is committed to complying with all applicable laws and regulations related to anti-corruption, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other international anti-corruption laws.

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Prohibited Activities

1. No employee or representative of Sentient Concepts shall engage in any form of corruption or bribery. This includes offering, giving, receiving, or soliciting bribes, kickbacks, or any improper payments.

2. We do not tolerate facilitation payments or "grease payments," even if they are customary in some regions.

3. No employee shall use company funds or assets for illegal or unethical purposes.

4. We do not engage in any transactions that are intended to conceal or launder the proceeds of corrupt activities.

 

Gifts and Entertainment

1. Reasonable and appropriate gifts and entertainment may be offered or accepted in the course of business. However, these should not be used to influence or gain an unfair advantage.

2. Employees must obtain prior approval from their manager or compliance officer for any gifts or entertainment valued above acceptable limits.

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Due Diligence

Sentient Concepts conducts due diligence on all business partners, vendors, and clients to ensure they have a reputation for ethical business practices. We refrain from engaging with individuals or entities involved in corrupt activities.

 

Reporting

1. Sentient Concepts encourages employees and stakeholders to report any suspected or observed instances of corruption or bribery.

2. We maintain a confidential and anonymous reporting mechanism to facilitate the reporting of such incidents.

3. Reports will be thoroughly investigated, and appropriate actions will be taken against those found to be in violation of this policy.

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Training and Awareness

Sentient Concepts provides regular anti-corruption training and education to employees to raise awareness of the risks associated with corruption and to ensure compliance with this policy.

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Consequences of Non-Compliance

Non-compliance with this Anti-Corruption Policy may result in disciplinary action, including but not limited to termination of employment, legal action, and civil or criminal penalties.

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Conclusion

Sentient Concepts is committed to maintaining the highest ethical standards in all aspects of our business. This Anti-Corruption Policy serves as a foundation for our efforts to prevent and combat corruption and bribery. All employees and stakeholders are expected to adhere to these principles, and we will continually strive to improve our anti-corruption efforts.

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Contact Us

If you have any questions or concerns about our anti-corruption policy, please contact us at digital@sentientconcepts.com.

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