This policy applies to Daturu Ltd and the people and organisations acting for or on its behalf.
1. Our commitment
Daturu Ltd is committed to conducting its business lawfully, honestly, fairly and with integrity.
We have zero tolerance for bribery, corruption, kickbacks or other unethical business practices. We comply with the UK Bribery Act 2010 and all other applicable anti-bribery and anti-corruption laws in the countries in which we operate.
2. Who this policy applies to
This policy applies to all directors, employees, contractors, consultants, agents, representatives and other parties acting for or on behalf of Daturu Ltd.
We also expect our suppliers, technology partners and other business partners to conduct themselves ethically and comply with applicable anti-bribery and anti-corruption laws.
3. Bribery and corruption
No person acting for or on behalf of Daturu Ltd may:
- offer, promise or give money, a gift, hospitality or any other advantage to influence a decision or obtain an improper business advantage;
- request, agree to receive or accept a bribe or improper advantage;
- offer or accept kickbacks, secret commissions or other undisclosed payments;
- use an agent, intermediary or other third party to make or receive an improper payment;
- make a facilitation payment to secure or accelerate a routine action; or
- offer an improper payment or advantage to a government official, public employee, political representative or member of their family.
These rules apply regardless of the value of the payment or benefit and whether the proposed recipient operates in the public or private sector.
4. Gifts, hospitality and entertainment
Reasonable and proportionate business hospitality may be offered or accepted where it:
- has a legitimate business purpose;
- is modest, infrequent and appropriate in the circumstances;
- is provided openly and transparently;
- is not intended to influence a decision or secure an improper advantage;
- could not reasonably be perceived as creating an obligation; and
- complies with applicable law and the recipient’s own policies.
Cash and cash-equivalent gifts must never be offered or accepted.
Gifts or hospitality involving government officials, or anything that may appear excessive or create a conflict of interest, must receive prior approval from a director of Daturu Ltd and be appropriately recorded.
5. Commissions, agents and third parties
Commissions, referral fees and payments to agents or intermediaries must relate to legitimate services, be reasonable and proportionate, and be supported by a written agreement and appropriate records.
Daturu Ltd will undertake proportionate checks before appointing third parties who may act on its behalf. Payments must not be made in cash, to an undisclosed recipient or through unusual arrangements intended to conceal the purpose or destination of the payment.
No third party may be used to undertake activity that would be prohibited if carried out directly by Daturu Ltd.
6. Political and charitable contributions
Daturu Ltd does not make political contributions intended to influence a business or governmental decision.
Charitable donations and sponsorships must be legitimate, appropriately approved and recorded. They must never be offered or used to obtain an improper business advantage.
7. Conflicts of interest
Anyone acting for Daturu Ltd must avoid situations in which personal, financial or other interests could improperly influence, or appear to influence, a business decision.
Actual or potential conflicts of interest must be disclosed promptly to a director so that they can be assessed and managed appropriately.
8. Accurate records
Daturu Ltd maintains accurate and complete financial and business records.
All payments, commissions, expenses, gifts and hospitality must be properly described and recorded. Undisclosed accounts, false descriptions, fabricated invoices and off-the-record payments are prohibited.
9. Raising a concern
Anyone who becomes aware of, or reasonably suspects, bribery, corruption or other unethical conduct connected with Daturu Ltd should report it promptly by emailing:
Concerns will be treated seriously and handled as confidentially as reasonably possible. No person will suffer retaliation or disadvantage for raising a genuine concern in good faith.
10. Breaches of this policy
Breaches of this policy may result in disciplinary action, termination of employment or termination of a commercial relationship. Where appropriate, suspected unlawful conduct may also be reported to the relevant authorities.
11. Responsibility and review
The directors of Daturu Ltd are responsible for overseeing this policy and promoting ethical conduct throughout the business.
The policy will be communicated to relevant personnel and reviewed periodically, taking account of the nature, scale and risks of Daturu Ltd’s activities.