TAM-C Solutions Anti-Bribery Policy

CONFIDENTIAL INFORMATION 

The upcoming policy focuses on anti-bribery and applies to all persons working for or on behalf of
TAM-C Solutions, including employees at all levels, directors, officers, agency workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners.

1. Policy Summary

Our Company operates in many jurisdictions and relies on the trust of consumers, business partners, and stakeholders. We are committed to conducting business with integrity and in full compliance with all applicable Anti-Bribery and Anti-Corruption (“ABAC”) laws.

This Policy prohibits:

  • Bribery of government officials (U.S. and non-U.S.)
  • Commercial / private-sector bribery
  • Offering, giving, promising, authorizing, or accepting anything of value to improperly influence business decisions
  • Facilitation payments, except in very limited emergency circumstances

Violation of this Policy or the Company’s Code of Conduct may result in disciplinary action, including termination, and could expose employees and the Company to civil or criminal liability.

2. Purpose and Goals of the Policy

The goals of this Policy are to:

  • Explain the legal and operational risks related to bribery and corruption
  • Define employee responsibilities under global ABAC laws
  • Establish clear procedures for interacting with government officials and third parties
  • Provide tools, processes, and resources to identify, mitigate, and escalate ABAC risks

Employees must read, understand, and comply with this Policy as part of their daily work.

3. Risks and Consequences of Non-Compliance

Failure to follow Anti-Bribery laws can result in:

  • Severe criminal and civil fines
  • Imprisonment for individuals
  • Loss of business licenses and contracts
  • Regulatory investigations
  • Significant reputational damage to the Company

Employees who violate this Policy may face disciplinary action up to and including termination.

4. Scope

This Policy applies globally to all employees, officers, and directors; temporary workers, contractors, and consultants; subsidiaries and controlled affiliates; and any third party acting on the Company’s behalf, including agents, distributors, intermediaries, brokers, and other representatives. All individuals covered by this Policy must avoid any activities that could create even the appearance of improper conduct. For purposes of the UK Bribery Act 2010, this Policy also applies to all “associated persons,” meaning any individual or entity that performs services for or on behalf of the Company, including employees, subsidiaries, agents, distributors, consultants, contractors, joint venture partners, and any third parties acting in a representative capacity.

5. Policy Requirements

5.1 Applicable Laws

Employees must comply with all applicable ABAC laws, including:

  • U.S. Foreign Corrupt Practices Act (FCPA)
  • UK Bribery Act (UKBA)
  • Local anti-corruption laws in all jurisdictions where we operate

These laws prohibit:

  • Bribery of government officials
  • Bribery in the private/commercial sector
  • Creation of inaccurate books, records, or off-book accounts
  • Failure to maintain adequate internal accounting controls

5.2 Prohibition of Bribery

5.2.1 Government Bribery

Employees may not offer, give, promise, or authorize anything of value to a government official to:

  • Obtain or retain business
  • Secure an improper advantage
  • Influence an official action or decision

Employees must also avoid the appearance of improper interaction with government officials.

5.2.2 Commercial Bribery

5.2.2A Giving Bribes

Offering, giving, requesting, or receiving improper benefits from private individuals or companies is strictly prohibited. This includes “kickbacks” or covert commissions.

5.2.2B Receiving Bribes

Employees, officers, and third parties acting on the Company’s behalf are strictly prohibited from soliciting, requesting, agreeing to receive, or accepting anything of value intended to improperly influence their actions or decisions. This prohibition applies to both government and commercial contexts.

5.2.3 Facilitation Payments

Facilitation or “grease” payments are prohibited except:

  • When personal safety is at risk
  • When explicit, documented prior written approval has been granted by Legal and Ethics & Compliance

Facilitation payments include small payments to expedite routine government actions (customs clearance, utilities, permits, licensing, etc.).

5.3 Providing Items of Value to Government Officials

5.3.1 Government Dealings Approval Process

Employees must obtain prior written approval from Legal (via the Company’s designated approval tool or workflow) before providing anything of value to a government official.

All such transactions must be accurately recorded in accordance with the Company’s accounting standards.

5.3.2 Gifts, Meals, Travel, and Entertainment (GME)

GME may never be used to improperly influence a decision.
Prohibited without exception:

  • Cash
  • Cash equivalents (gift cards, vouchers)

Prior written approval is required before providing GME to a government official.

5.3.3 Donations

Donations may not be used to influence an official.
Charitable contributions to government agencies require prior approval and must be properly documented.

5.3.4 Promotional Activities

Promotional expenses targeted to government entities (e.g., demonstrations, product explanations) must receive prior approval and be legitimate, documented, and non-improper.

5.3.5 Hiring Government Officials or Relatives

Hiring or engaging:

  • A government official, or
  • A government official’s family member

requires prior written Legal approval.
Hiring may not be used to improperly influence official actions.

5.3.6 Political Contributions

Political contributions require prior approval through the designated Corporate process.
Political contributions must never be used to obtain a business advantage.

5.3.7 Limited Exceptions

Limited exceptions to pre-approval may apply when:

  • A blanket approval is in place
  • Personal safety is at risk
  • Approval cannot be obtained in time (must be documented and escalated)

Consult Legal for additional guidance.

5.4 Third-Party Management

5.4.1 Applicability

Third parties acting on behalf of the Company are strictly prohibited from making corrupt payments.

Payments to third parties must:

  • Be customary and reasonable
  • Be tied to legitimate services
  • Never be made in cash (unless pre-approved in writing)
  • Be made only to properly documented bank accounts in the third party’s name

5.4.2 Due Diligence

All third parties interacting with government entities on the Company’s behalf must go through the Company’s due diligence process before work begins.

Requirements include:

  • Screening and risk assessment
  • Review of ownership, services, and government touchpoints
  • Addressing and documenting any red flags
  • Written contracts including ABAC provisions
  • Renewal of due diligence every three years

Ongoing monitoring of third-party activity is required for the duration of the relationship.

5.5 Certification

Employees subject to internal control or financial reporting requirements must provide periodic (e.g., quarterly) certifications confirming compliance with this Policy and accuracy of relevant records.

5.6 Training

The Company requires ABAC training for:

  • All managers
  • All employees in designated risk roles (sales, procurement, government affairs, strategic security, etc.)
  • Additional personnel identified by Legal or Compliance

Training may include:

  • Online modules
  • In-person or instructor-led sessions
  • Code of Conduct courses

Completion of assigned training is mandatory.

5.7 Auditing

The Company conducts periodic internal audits to ensure compliance with ABAC laws and this Policy.

Employees must:

  • Fully cooperate
  • Not interfere with audits or investigations
  • Provide all relevant documentation upon request

Auditors maintain independence and consult Legal and Compliance on interpretation questions.

5.8 Reporting Violations

Employees must promptly report:

  • Suspected violations of this Policy
  • Improper conduct by employees or third parties
  • Requests for improper payments

Reports may be made to:

  • Legal
  • Ethics & Compliance
  • A designated hotline or ethics portal

Reports will be treated confidentially where permitted by law.
Retaliation against good-faith reporting is strictly prohibited.

Failure to report violations is itself a breach of this Policy.

5.9 Books, Records, and Internal Accounting Controls

In accordance with the FCPA, the Company must maintain accurate books, records, and accounts that reflect all transactions in reasonable detail. Off-book accounts, unrecorded funds, or falsified entries are strictly prohibited.

The Company maintains internal accounting controls designed to ensure that all transactions are properly authorized, documented, and recorded, including segregation of duties, approval workflows, and supporting documentation for all expenses, gifts, payments, and third-party engagements.

5.10 System of Adequate Procedures

The Company maintains a system of Adequate Procedures consistent with the UK Bribery Act 2010, including proportionate policies, top-level commitment, documented risk assessments, due diligence on associated persons, communication and training, and ongoing monitoring and review of the effectiveness of this Policy.

6. Document Retention

All records relating to Anti-Bribery approvals, due diligence, training, audits, and reporting must be retained in accordance with the Company’s record retention policy.

7. Enforcement

Violations of this Policy may result in:

  • Disciplinary action up to termination
  • Civil or criminal liability
  • Reporting to regulatory authorities
  • Termination of third-party relationships

Any indication or report of violations or suspicions of violations can be reported at compliance@tamcintel.com.