Anti-Bribery and Anti-Corruption Policy
Our position on bribery and corruption, and the specific rules that follow from it.
Our position
ASTRI DEVS LTD does not offer, give, request or accept a bribe. We do not tolerate bribery or corruption in any form, in any market, by anyone acting for us. This applies whether or not the conduct would be usual in a particular sector or country.
We comply with the Bribery Act 2010, and with equivalent legislation wherever we operate. We hold no external certification in relation to this policy and do not claim any; this is a statement of how the company operates.
Who this applies to
Everyone acting for or on behalf of ASTRI DEVS LTD: directors, employees, contractors, subcontractors, delivery partners and agents. Where we engage a subcontractor or delivery partner, compliance with this policy is a condition of that engagement.
Facilitation payments
We do not make facilitation payments — small unofficial payments to speed up a routine action a person is already obliged to perform. There is no exception for local custom or commercial inconvenience. If a payment of this kind is demanded, the answer is no, and the demand is reported to a director.
The single exception is a genuine and immediate threat to someone's personal safety, where a payment made under duress must be reported to a director as soon as it is safe to do so and recorded accurately.
Gifts and hospitality
Reasonable and proportionate business hospitality is acceptable. To be acceptable, it must:
- be given openly, in our name, and not in cash or a cash equivalent;
- be intended to build a working relationship or present our services, not to influence a decision;
- be of a scale that would not embarrass either party if it appeared in a published register;
- not be offered or accepted during a live tender, procurement or bid evaluation; and
- comply with the rules of the recipient's own organisation, which take precedence over ours.
Public-sector and regulated-sector rules are frequently stricter than this policy. Where they are, they apply. If in doubt, decline.
Conflicts of interest
Anyone acting for us who has a personal, financial or family interest that could affect, or reasonably appear to affect, a decision on an engagement must declare it to a director before the decision is taken. Declared conflicts are recorded, and the person concerned is removed from the decision.
Where we bid for work and hold a relationship with another party to that procurement, we disclose it to the buying organisation. We would rather lose a bid than win one that is subsequently challenged.
Suppliers and subcontractors
Before we engage a supplier or subcontractor on client work, we check their legal identity and make our anti-bribery expectations a term of the engagement. We do not engage a party we have reason to believe engages in bribery or corruption, and we terminate where evidence emerges during an engagement.
Raising a concern
Anyone — including a client, a supplier or a member of the public — can raise a concern about bribery or corruption involving ASTRI DEVS LTD by emailing info@astridevs.co.uk, marked for the attention of a director.
Concerns are taken seriously and investigated. Nobody raising a genuine concern in good faith will suffer any detriment for doing so, even if the concern turns out to be mistaken. Where a concern is raised anonymously we will still investigate, though we may be limited in what we can find out.
Records
Financial records are kept accurately and transparently, and describe the substance of what actually happened. No account, invoice or record may be created that is false or misleading, and no payment may be made without a genuine, documented business purpose.