Think Digital Partners Anti-Corruption Policy 2023
This Policy establishes Think Digital Partners anti-corruption policy and applies in all places where Think Digital Partners conducts business.
This Policy applies to all Think Digital Partners personnel, including regular employees, interns, Think Digital Partners-paid temporary employees, and contingent workers (including agency temporary employees, independent contractors, and vendor employees).
This Policy also applies to all Third Parties (as defined in this Policy) who act on behalf of Think Digital Partners, including but not limited to any distributor, reseller, business partner, supplier, intermediary, consultant, representative, contractor, subcontractor, or agent of Think Digital Partners.
Think Digital Partners is committed to complying with all applicable anti-corruption laws, including the U.K. Bribery Act, and any local anti-corruption laws. If applicable laws are stricter than this Policy, Think Digital Partners will comply with those laws.
Think Digital Partners prohibits bribes or payments of anything of value intended to improperly influence anyone. It is against Think Digital Partners policy to provide, offer, promise, accept, solicit, authorise or coordinate payments of anything of value to anyone for the purpose of obtaining an unfair advantage for Think Digital Partners. A bribe can be anything of value to the intended recipient or their friends or family members. Depending on the circumstances, a bribe may include but is not limited to:
• cash or cash equivalents like gift cards; • lavish gifts, meals or hospitality; • travel expenses not related to any business matter; • charitable donations or political contributions to gain the favour of someone who can influence business with Think Digital Partners; • billing schemes, such as excessive discounts, commissions, or payments of fake or excessive invoices, which result in “slush fund” money being used to make improper payments; • employment or promises of future employment, for the recipient or their family member • any personal favours, such as helping to secure school admission, paying personal bills, or allowing the use of personal vehicles or vacation homes.
A key characteristic of a bribe is that it urges the intended recipient of the bribe to misuse their power or position. A prohibited bribe is anything that creates or may create an expectation that the recipient will act improperly in return.
A prohibited bribe is also any payment or offer made for the purpose of obtaining an unfair commercial benefit for Think Digital Partners. For example, it is never acceptable to pay a bribe to promote or secure the sale of Think Digital Partners products or services, obtain favourable treatment, circumvent or meet a government license or permit requirement, or gain access to non-public information.
Offering or promising to pay a bribe is a violation of this Policy, even if the payment is not actually received or accepted.
Think Digital Partners prohibits the indirect payment of bribes through Third Parties, such as partners, sales agents or suppliers. It is prohibited to authorize or coordinate a Third Party to pay a bribe on Think Digital Partners behalf, regardless of whether Think Digital Partners resources are used to pay the bribe.
To help ensure that Think Digital Partners conducts business with integrity and in compliance with laws, all Think Digital Partners personnel are required to follow the anti-corruption compliance procedures described in this Policy.
Think Digital Partners has established the following procedures to prevent bribery and corruption in the course of its business dealings. You are expected to comply with these procedures and use good judgment at all times, and to refrain from making or accepting any payment or gesture that may be considered a bribe – even if a particular scenario is not specifically addressed in this Policy.
Cash and cash equivalents, such as pre-paid cash cards, re-loadable debit cards or gifts cards, are prohibited and may not be given to or accepted from any outside (non- Think Digital Partners) party unless you are expressly authorised by a Think Digital Partners policy or you have been preapproved by the Company Director.
Gifts and hospitality, regardless of value, must be avoided if they may improperly influence, or appear to influence, the recipient’s actions or business judgment. This will depend on the facts of the particular situation, including the purpose and value of the gift or hospitality, who the recipient is, and whether they have any responsibility or involvement in any upcoming business decision impacting Think Digital Partners. In appropriate circumstances, gifts and hospitality, including meals or entertainment, may be given or received so long as they are reasonable and appropriate in nature and value, customary to the occasion, and related to a legitimate business purpose (such as a meeting to explain or promote Think Digital Partners products or services). All gifts and hospitality must be exchanged in a transparent manner and must be properly documented.
Think Digital Partners may pay for reasonable travel and lodging expenses for outside (non- Think Digital Partners) parties to attend meetings or events that promote Think Digital Partners products or services.
This policy has been approved by Matt Stanley, Co-Founder and Director for Think Digital Partners.