1. Introduction
At TESTQ Technologies Limited (“TESTQ”, “we”, “our”, or “the Company”), we are committed to conducting business with integrity, fairness, and transparency. Bribery and corruption are illegal, unethical, and undermine trust in business relationships. This Anti-Bribery and Corruption Policy (“Policy”) outlines our commitment to comply with the UK Bribery Act 2010, as well as other applicable anti-corruption laws and regulations in the regions where we operate.
2. Scope
This Policy applies to:
• All employees, officers, and directors of TESTQ.
• Contractors, consultants, agency staff, and temporary workers engaged by TESTQ.
• Third parties acting on behalf of TESTQ, including suppliers, partners, intermediaries, and agents.
3. Policy Statement
TESTQ has a zero-tolerance approach to bribery and corruption. Specifically:
• No employee or associated person may offer, promise, give, request, or accept a bribe in any form.
• Facilitation payments (small unofficial payments to secure routine actions) are prohibited.
• Kickbacks, secret commissions, or any corrupt inducements are strictly forbidden.
• Political donations are not permitted unless approved by the Board and compliant with applicable law.
• Charitable contributions and sponsorships must be transparent, properly recorded, and not used as a means to influence business decisions.
4. Definitions
• Bribery: Offering, promising, giving, requesting, or accepting anything of value to improperly influence business outcomes.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Unofficial payments to expedite routine actions (e.g., customs clearance).
• Gifts & Hospitality: Legitimate business courtesies may be acceptable if they are modest, proportionate, and transparent.
5. Responsibilities
• Employees: Must comply with this Policy, undertake relevant training, and immediately report any suspected breach.
• Managers: Must lead by example, ensure their teams understand the Policy, and monitor compliance.
• Suppliers/Third Parties: Must adhere to TESTQ’s Anti-Bribery and Corruption standards and demonstrate compliance in contracts and practices.
6. Gifts and Hospitality
Gifts and hospitality must:
• Be of modest value and appropriate under the circumstances.
• Be given openly, not secretly.
• Never influence, or appear to influence, a business decision.
7. Due Diligence
TESTQ conducts proportionate due diligence when engaging suppliers, contractors, or agents to assess risks of bribery and corruption. This includes background checks, compliance confirmations, and contractual anti-bribery clauses.
7. Record-Keeping
All financial transactions, expenses, and approvals must be accurately and transparently recorded. False or misleading records will not be tolerated.
9. Reporting and Whistleblowing
Employees and third parties are encouraged to report concerns about suspected bribery or corruption.
• Reports can be made confidentially via testq@testqtech.com
• TESTQ ensures no retaliation against whistleblowers acting in good faith.
10. Training and Communication
• Employees in high-risk functions (e.g., procurement, recruitment, business development) must complete mandatory anti-bribery training.
• This Policy will be communicated to suppliers and contractors.
11. Monitoring and Review
The Board of Directors oversees compliance with this Policy. Regular reviews and audits will ensure effectiveness, identify risks, and update measures in line with evolving laws and best practices.