Contact Us

Governance & ethics policy · Handbook ref. 11.5

Anti-Bribery, Anti-Corruption & AML Policy

How Tristha Global Pvt Ltd identifies, prevents and responds to bribery, corruption and money laundering risk across our business — for every employee, director, contractor and partner acting on our behalf.

 
Applies to Owner Source Tolerance
All employees & directors Human Resources & Legal HR Handbook v2.3, §11.6–11.7 Zero

On this page

11.6 Our commitment

Tristha Global Pvt Ltd places the utmost importance on honesty and integrity in every business activity we undertake. We are committed against illegal payments and other corrupt practices in any form, in any market we operate in.

This policy sets out our approach to preventing bribery, corruption and money laundering, and the standards we expect from everyone who works for or represents the company.

Guiding principle: We do not offer, promise, give, request or accept anything of value in exchange for improper business advantage — directly or through anyone acting on our behalf.

11.6.1 Who this applies to

Our Anti-Bribery, Anti-Corruption and Anti-Money Laundering (ABC/AML) policy applies to all employees and directors of Tristha Global Pvt Ltd, without exception of seniority or role.

It also extends in spirit to anyone acting on the company’s behalf — including consultants, agents, contractors and business partners — who are expected to uphold the same standards when representing us.

11.6.2 Key definitions

Understanding these terms is the first step to recognising and avoiding a breach of this policy.

Bribery
An inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe.

Corruption
Wrongdoing on the part of an authority or those in power, through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is closely associated with bribery.

Money laundering
Disguising the origin of funds obtained through illegal activity so they appear to come from a legitimate source. AML controls exist to stop our business being used, knowingly or not, as a channel for this.

Facilitation payment
A small, informal payment made to secure or speed up a routine action a person is already entitled to. These are treated the same as bribes under this policy and are not permitted.

11.6.3 What is prohibited

The following are strictly prohibited, regardless of local custom, competitive pressure or business urgency:

  • Offering, promising or giving any bribe, kickback or improper payment to a public official, customer, supplier or any other individual.
  • Requesting, agreeing to receive, or accepting any bribe, kickback or improper payment.
  • Using a third party — an agent, consultant, distributor or intermediary — to do indirectly what the company cannot do directly.
  • Making or facilitating a facilitation payment of any kind, however small.
  • Processing, transferring or accepting funds where there is reasonable suspicion the source is illegitimate.
  • Turning a blind eye to any of the above, or failing to raise a genuine concern about them.

11.7 Gifts & hospitality

The practice of giving gifts and hospitality is recognised as an established and important part of doing business. Receiving or giving gifts or hospitality is acceptable under this policy only if all of the following requirements are met.

Acceptable gift or hospitality — all three must be true:
  1. No exchange intended — It is not made with the intention of exchange for favours, benefits, or for any other corrupt purpose.
  2. Never cash or a cash equivalent — It does not include cash or a cash equivalent, such as a gift voucher or certificate.
  3. Given openly — It is given openly, not secretly, and in a manner that avoids the appearance of impropriety.
If any one of these three conditions cannot be met, the gift or hospitality must be declined, returned, or — where appropriate — redirected through the correct approval channel before proceeding.

11.6.4 Third parties & business partners

We only work with third parties who share our commitment to ethical business conduct. Before engaging an agent, consultant, distributor or supplier who will represent us externally, reasonable due diligence should be carried out proportionate to the risk involved.

11.6.5 Reporting a concern

Anyone who suspects a breach of this policy — including a request for a bribe, an offer that seems improper, or suspicious financial activity — is expected to raise it promptly. Concerns raised in good faith are taken seriously, and the company does not tolerate retaliation against anyone who reports one.

How to raise a concern: Speak to your reporting manager, or contact Human Resources.

11.6.6 Consequences of non-compliance

Zero tolerance: A breach of this policy is treated as serious misconduct and may result in disciplinary action up to and including termination of employment or contract.
Corporate Policies
  • Policy 1
  • Policy 2
  • Policy 2