Anti-Bribery & Corruption Policy
Purpose and scope
IsoGentiX Ltd is committed to conducting all business ethically and in full compliance with anti-bribery and anti-corruption laws wherever we operate. This policy applies to all directors, employees, contractors, agents, and any person acting on behalf of IsoGentiX in any jurisdiction.
The primary legal framework this policy is designed to satisfy is the UK Bribery Act 2010. Where IsoGentiX operates in jurisdictions with equivalent or additional requirements — including Madagascar and EU Member States — the higher standard applies.
Prohibited conduct
The following are strictly prohibited in all circumstances:
- Offering, promising, or giving a bribe — any financial or other advantage — to any person, including public officials, national authority personnel, or commercial counterparties, to obtain or retain business, secure a permit, or gain any improper advantage
- Requesting, agreeing to receive, or accepting a bribe
- Bribing a foreign public official under the Bribery Act 2010 s.6
- Facilitation payments — small payments to officials to perform routine functions they are already obliged to perform — even where these are locally common practice
- Authorising or condoning bribery by a third party acting on IsoGentiX's behalf
Gifts, hospitality, and expenses
Genuine hospitality and reasonable business gifts are not automatically prohibited, but must be:
- Modest in value and appropriate to the business context
- Not offered or received in circumstances that could be perceived as intended to influence a business or regulatory decision
- Recorded in the gifts and hospitality register
- Pre-approved by a director for any item above £50 in value
Cash gifts are never permitted in any amount.
Third parties and due diligence
IsoGentiX may be held liable for bribery committed by third parties acting on our behalf. All agents, intermediaries, and third-party representatives engaged to interact with national authorities or commercial counterparties on IsoGentiX's behalf must be subject to due diligence checks before engagement, and must contractually commit to compliance with this policy.
Reporting and non-retaliation
Any person who suspects a violation of this policy must report it immediately to a director or via the Grievance Policy process. No person will be penalised for refusing to participate in conduct that would violate this policy, or for reporting a concern in good faith. Retaliation against a person who raises a concern is itself a disciplinary matter.
Consequences of violation
Violations of this policy may result in immediate termination of employment or engagement, civil liability, criminal prosecution, and reputational harm to IsoGentiX. The company will not provide assistance — legal, financial, or otherwise — to any individual facing prosecution for bribery committed in connection with IsoGentiX activities.