This Anti-Bribery and Anti-Corruption Policy (the “Policy”) is established to ensure LUNIQ Limited (12410828) complies with the Bribery Act 2010 and any other applicable anti-corruption laws. The Policy underscores our commitment to ethical business conduct, transparency, and zero tolerance towards bribery and corruption.

 

Scope

This Policy applies to all employees, officers, directors, consultants, contractors, agents, and any other individuals or entities acting on behalf of LUNIQ (collectively, “Personnel”). It also extends to our business partners, suppliers, and other third parties associated with the company.

 

Policy Statement

LUNIQ prohibits:

  • Offering or receiving bribes of any form.
  • Engaging in or tolerating corruption or unethical conduct.
  • Making facilitation payments, even if customary in certain countries.
  • Indirect involvement in bribery through third parties, agents, or other intermediaries.

All business dealings must be conducted with integrity, transparency, and in compliance with applicable laws.

 

Gifts and Hospitality

Reasonable and proportionate gifts and hospitality are permissible if:

  • They are not intended to influence decision-making.
  • They comply with local laws and company policies.
  • They are appropriately recorded in the company’s gift register.

Extravagant, frequent, or concealed gifts are strictly prohibited.

 

Donations and Sponsorships

  • Political Donations: LUNIQ does not make political donations.
  • Charitable Donations: Charitable donations are allowed if they are transparent, documented, and not intended to influence a business decision.

Facilitation Payments

Facilitation payments are prohibited, even in countries where such payments may be considered customary. Any demands for such payments must be reported immediately.

Record-Keeping

All financial records must be maintained accurately and transparently. Personnel must record and report:

  • All gifts, hospitality, or donations received or offered.
  • Any suspected or actual instances of bribery or corruption.

Reporting and Whistleblowing

Personnel are encouraged to report any suspected or actual instances of bribery or corruption through the company’s whistleblowing channels. Reports will be handled confidentially, and the company is committed to protecting whistle-blowers from retaliation.

Training and Communication

LUNIQ will provide regular training on anti-bribery and anti-corruption policies. This Policy will be made available to all employees and third parties.