Anti-Bribery and Corruption Policy

Purpose

Air Aware Labs is committed to conducting business ethically, responsibly, and in compliance with applicable laws. This policy aims to prevent bribery and corruption in all business dealings, ensuring integrity and transparency.

Scope

This policy applies to:

  • All employees, contractors, officers, and directors of Air Aware Labs.
  • Third parties, including consultants, suppliers, and partners, when acting on behalf of the company.

Definitions

  • Bribery: Offering, promising, giving, or receiving something of value to influence a business outcome.
  • Corruption: Abuse of entrusted power for personal or business gain.
  • Facilitation Payments: Small, unofficial payments made to expedite routine government actions.

Policy Statements

  1. Prohibition of Bribery and Corruption
    • Employees and representatives must not offer, promise, give, or receive any bribes or engage in corrupt practices.
    • Facilitation payments are strictly prohibited unless there is a direct threat to health or safety.
  2. Gifts and Hospitality
    • Gifts, hospitality, or expenses must be reasonable, proportionate, and compliant with company guidelines.
    • Any gifts or hospitality exceeding a value of £1,000 must be declared and approved by management.
  3. Third Parties
    • Air Aware Labs conducts due diligence on third-party partners to ensure compliance with this policy.
  4. Donations
    • Political or charitable donations must not be used to gain an improper business advantage.
    • All donations must be approved by senior management.

Reporting and Whistleblowing

  • Employees are required to report any suspicions of bribery or corruption immediately to their manager.
  • Reports can be made anonymously, and whistleblowers are protected from retaliation.

Monitoring and Compliance

  • The company reserves the right to monitor and audit business activities to ensure compliance.
  • Any breach of this policy may result in disciplinary action, up to and including termination of employment or partnership.

Responsibility

  • The CEO and management team are responsible for implementing and enforcing this policy.

Review

This policy will be reviewed annually or when there are significant legal or business changes. This statement is available on the Air Aware Labs website or by contacting hello@airawarelabs.com.

Effective Date: 24/01/2025
Version: 1.0