Anti-Bribery Policy

Introduction

Compliance with this policy is mandatory, and failure to comply may result in disciplinary action, including termination and potential legal consequences.

Definition of bribery

Bribery refers to the offering, giving, receiving or solicitation of any form of improper advantage, financial or otherwise, to influence the actions, decisions or behaviour of an individual or organisation in a position of trust, to gain or retain business or secure an improper advantage. Bribery can occur in both the public and private sectors and includes facilitation payments, kickbacks and any form of illegal gratuities.

Prohibited conduct

• Bribery. No employee or representative of Think Rugs shall offer, promise or give anything of value, directly or indirectly, to any person or organisation with the intention to improperly influence their actions or decisions.
• Solicitation. No employee or representative of Think Rugs shall solicit, request or accept any bribe or improper advantage from any person or organisation, whether directly or indirectly, in connection with their duties or business activities.
• Facilitation payments. Facilitation payments, also known as “grease payments”, are small unofficial payments made to expedite routine governmental actions. Think Rugs prohibits any facilitation payments unless explicitly permitted under applicable local laws and regulations and pre-authorised by the appropriate level of management.
• Gifts and hospitality. Employees must exercise caution when giving or receiving gifts, entertainment or hospitality. No gift, entertainment or hospitality should be given or received if it creates a real or perceived conflict of interest or is intended to influence a business decision.
• Political contributions. Think Rugs prohibits any direct or indirect political contributions, donations or payments to political parties, candidates or public officials, unless explicitly authorised and in compliance with applicable laws and regulations.

Due diligence and risk assessment

Think Rugs will implement appropriate due-diligence procedures to assess the integrity, reputation and business practices of our partners, suppliers, agents and any third parties with whom we engage in business. These procedures may include background checks, financial audits and compliance certifications.

Training and communication

Think Rugs will provide regular training programmes to employees, contractors and representatives to ensure their understanding of this policy, applicable laws and the consequences of non-compliance. We will also communicate this policy to all relevant stakeholders, including suppliers, agents and third parties.

Compliance and consequences

Failure to comply with this policy may result in disciplinary action, including termination, and may be subject to legal consequences, including fines and imprisonment. Think Rugs will cooperate fully with law-enforcement authorities in any investigations related to bribery or corruption.

Policy review

This Anti-Bribery Policy will be reviewed periodically to ensure its continued effectiveness and compliance with evolving laws and best practice. Any necessary updates or amendments will be communicated to all relevant stakeholders.

By adhering to this policy, we uphold our commitment to fair and ethical business practices, fostering a culture of integrity within Think Rugs and maintaining the trust of our stakeholders.