Anti-Bribery & Corruption Policy

4Syte Secured Finance

It is the policy of 4Syte Secured Finance Ltd (Company or we) to conduct all of its business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

The Company prohibits the offering, giving, solicitation or the acceptance of any bribe, whether cash or other inducement, to or from any person or company, wherever they are situated, and regardless of whether they are a public official, private person or company by any member of staff, agent or other person or body acting on the Company’s behalf in order to gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical or in order to gain any personal advantage, monetary or otherwise, for the individual or anyone connected with the individual. This prohibition applies in all cases, but specific examples include attempting to win business, keep business, or gain a business advantage for the Company.

Likewise, we expect and rely on all and every person performing services for us or on our behalf (Associated Person) to:
- to share our values and our approach to bribery and corruption and comply with all applicable laws, statutes, regulations relating to anti-bribery and anti-corruption including but not limited to the Bribery Act 2010 (Relevant Requirements);
- have and shall maintain in place throughout the term of dealing with us its own policies and procedures, including adequate procedures under the Bribery Act 2010, to ensure compliance with the Relevant Requirements and will enforce them where appropriate;
- promptly report to us any request or demand for any undue financial or other advantage of any kind received by the Associated Person in relation with the services provided to us or performed on our behalf;
- immediately notify us (in writing) if a foreign public official becomes an officer or employee of the Associated Person and the Associated Person warrants that it has no foreign public officials as officers or employees at the date of commencing to provide services to us or perform services on our behalf;

Any and every Associated Person shall ensure that any person associated with it who is performing services in connection with services provided to us or performed on our behalf does so only by complying with stipulations (a) to (d) above mutatis mutandis (Relevant Terms). The Associated Person shall be responsible for the observance and performance by such persons of the Relevant Terms, and shall be directly liable to us for any breach by such persons of any of the Relevant Terms.