Last Revised: 08 December 2021
Coinhako is fully committed to ensuring that all its employees, and Coinhako as an entity, comply with all anti-bribery and corruption laws in all jurisdictions where Coinhako operates.
Coinhako has zero tolerance for bribery and corruption.
Corrupt behaviour is defined as dishonestly acting, or dishonestly failing to act, in the performance of functions of one’s employment, or dishonestly taking advantage of one’s employment to obtain benefit for himself or herself, the Company or for another person or organisation, or to cause loss to another party / person.
Bribery is defined as the act of
- Providing, offering or causing a benefit to another person with the intention of influencing for a business or personal advantage, where the benefit is not legitimately due and regardless of whether the recipient is the intended target of the benefit;
- Soliciting or receiving a benefit from another person with the intention of providing a business or personal advantage, where the benefit is not legitimately due; or
- Inducing or permitting a third party to provide, offer or cause a benefit to another person with the intention of influencing for a business or personal advantage, where the benefit is not legitimately due regardless of whether the recipient is the intended target of the benefit.
In determining whether corruption or bribery has occurred, the benefit received may be monetary or otherwise. Bribery can involve the giving, receiving or acceptance of any gift, reward, hospitality or other offer which could be perceived as an incentive, favour or inducement to perform an improper act or gain a business or personal advantage.
Coinhako will uphold the following standards relating to all matters concerning anti-bribery or anti-corruption.
- Coinhako strictly prohibits all forms of bribery and corruption, including facilitation payments. The Company will report all instances of bribery and corruption to the relevant authorities without exception.
- When receiving or giving gifts and/or providing entertainment, employees must ensure that that gifts and/or entertainment are reasonable and proportionate to the purpose for which they are given or taken.
- All employees shall report any issues of conflict of interest before giving or receiving gifts.
- All questionable behaviour should be reported to the relevant reporting officer(s), and all suspicions of impropriety relating to corruption or bribery should be reported to management directly or via the Company’s whistleblowing channels.
- Employees should exercise heightened care and diligence when interacting with public officials.