Anti-Bribery & Anti-Corruption Policy

1. Introduction

UDGI Foundation is committed to the highest standards of integrity, transparency, and accountability. We adopt a zero‑tolerance stance on bribery, corruption, fraud, and other unethical conduct, ensuring compliance with all applicable anti‑corruption laws.

2. Purpose

To clearly define responsibilities and procedures to prevent, identify, and remedy bribery and corruption in all activities involving UDGI staff, partners, and stakeholders.

3. Scope

This policy applies to:

• All UDGI employees (permanent, temporary, consultants, interns, volunteers).

• Third parties acting on UDGI’s behalf (partners, agents, contractors, intermediaries).

4. Policy Statement

• Bribery: Prohibited in all forms—offering, promising, giving, accepting, or soliciting any advantage for improper purpose.

• Corruption: Misusing entrusted power for personal gain is strictly forbidden.

• UDGI adheres to a zero‑tolerance approach and expects the same from its affiliates. 

5. Objectives

• Promote vigilance and integrity in all actions.

• Mitigate risks related to bribery and corruption.

• Establish transparent monitoring, complaint, and enforcement practices.

• Protect UDGI’s reputation by holding all associated individuals accountable. 

6. Key Principles

• UDGI leadership must exemplify ethical conduct and anti‑corruption behavior.

• Zero tolerance across all levels—no exceptions.

• Third parties working with UDGI must comply fully with this policy. 

7. Covered Areas

Prohibited activities include (but are not limited to):

• Bribes (cash, gifts, favors).

• Excessive/unrecorded gifts, hospitality, entertainment.

• Facilitation payments.

• Charitable or political contributions intended to gain unlawful advantage. 

Permitted (only if):

• Gifts/hospitality are moderate, well-documented, and directly related to a legitimate business purpose.

• Formal approval and recording procedures are followed. 

8. Compliance & Monitoring

• Regular internal/external audits and transaction reviews.

• Financial records must be accurate, transparent, and complete.

• Any exception requires written approval by UDGI’s President and Secretary. 

9. Reporting and Investigation

• Reports of suspected bribery/corruption must be submitted in writing to the Anti‑Corruption Committee within 5 working days.

• Committee composition:

  • Chairperson (Anti‑Corruption Committee)

  • Two mid‑level team members (gender balanced)

  • Head of HR Investigations conducted promptly, aimed at resolution within 10 working days. 

• Appeals submitted to the President within 10 days; resolution within 15 working days via an independent review panel. 

10. Confidentiality & Privacy

• All reports kept confidential, protecting both complainant and respondent.

• If allegations are unsubstantiated, no record will be retained in personal files; documentation maintained securely for 12 months. 

11. Sanctions & Enforcement

• Non‑compliance results in disciplinary actions, including suspension or termination.

• Third parties may be disqualified from contracts or partnerships. 

12. Roles & Responsibilities

• Board/Leadership: Ensure ethical integration and accountability.

• Managers: Reinforce policy awareness and positive culture.

• Employees and Third Parties: Learn, comply, and report any misconduct.

13. Training & Awareness

• All relevant staff and partners will receive initial and ongoing training on anti‑bribery norms, with records maintained.

• Annual refresher programs to keep awareness high.

14. Review & Revision

• This policy undergoes annual review or upon major changes in law, structure, or operations.

• Updates will be communicated to all stakeholders.

Governance
Oversight by the Anti‑Corruption Committee, supported by the Board and HR department. Full documentation of training events, complaints, audits, and policy revisions will be maintained for transparency and compliance.