Anti-Corruption Policy

1. Policy Statement

Amicus Talent Solutions is committed to conducting business with the highest standards of integrity and ethics. We have a zero-tolerance approach to bribery and corruption and are dedicated to implementing effective systems to counter bribery in all our business dealings and relationships.

2. Purpose

This policy outlines our commitment to preventing bribery and corruption within our organization and sets forth the standards and procedures to ensure compliance with applicable anti-corruption laws and regulations.

3. Scope

This policy applies to all employees, contractors, suppliers, and business partners of Amicus Talent Solutions across all locations.

4. Definitions

  • Bribery: Offering, giving, receiving, or soliciting something of value as a means to influence the actions of an individual in a position of authority.

  • Corruption: Abuse of entrusted power for private gain, including bribery, fraud, and other unethical practices.

5. Prohibited Conduct

  • Offering or Receiving Bribes: Employees and associated persons must not offer, give, solicit, or receive bribes or other improper payments.

  • Facilitation Payments: Employees must not make or accept facilitation payments, which are small bribes to expedite routine governmental actions.

  • Gifts and Hospitality: Offering or accepting gifts and hospitality is permissible only if it is reasonable, proportionate, and transparent, and does not influence business decisions.

6. Responsibilities

  • Management: Ensure the implementation of this policy, allocate necessary resources, and monitor compliance.

  • Employees: Adhere to the policy, participate in training, and report any concerns regarding bribery or corruption.

  • Suppliers and Partners: Comply with our anti-corruption standards and cooperate in our efforts to prevent bribery and corruption.

7. Reporting and Whistleblowing

Employees are encouraged to report any concerns or suspicions of bribery or corruption through established reporting channels. Reports can be made confidentially, and retaliation against individuals who report in good faith is strictly prohibited.

8. Compliance and Monitoring

We will regularly monitor and review our anti-corruption practices to ensure their effectiveness. Non-compliance with this policy may result in disciplinary action, including termination of employment or contracts.

9. Review

This policy will be reviewed annually to ensure its effectiveness and relevance.

10. Approval

This policy has been approved by the Board of Directors of Amicus Talent Solutions and is effective as of January 1st 2025.