Anti-Corruption Policy

This Anti-Corruption Policy is effective dated: June 01, 2024

Control Document: GEF-CP-002, Ver. 1.0

Purpose

The purpose of this Anti-Corruption Policy is to ensure that galaxefi operates in a fair, ethical, and transparent manner, in full compliance with applicable anti-corruption laws and regulations. This policy aims to prevent any form of corruption or bribery within the organization and its interactions with third parties.

Scope

This policy applies to all employees, officers, directors, contractors, consultants, vendors, suppliers, and any other third parties acting on behalf of galaxefi.

Policy Statement

galaxefi strictly prohibits any form of bribery or corruption. This includes offering, giving, soliciting, or accepting any financial or other advantage in order to influence the actions of an individual, organization, or government official in the performance of their duties.

Definitions

  • Bribery: Offering, promising, giving, accepting, or soliciting something of value as a means of influencing the actions of an individual in the discharge of their duties.
  • Corruption: Dishonest or fraudulent conduct by those in power, typically involving bribery.

Prohibited Activities

  • Bribery of Government Officials: Employees and third parties are prohibited from offering, promising, giving, or authorizing any financial or other advantage to a government official or to any other person to obtain or retain business or an advantage in the conduct of business.
  • Commercial Bribery: Employees and third parties are prohibited from offering, promising, giving, or authorizing any financial or other advantage to a private individual to induce or reward the improper performance of a function or activity.
  • Facilitation Payments: galaxefi prohibits facilitation or “grease” payments, which are typically small payments made to secure or expedite routine government actions

Gifts and Hospitality

Gifts and hospitality must be reasonable, proportionate, and not intended to influence business decisions. All gifts and hospitality must be reported and recorded in accordance with galaxefi‘s procedures.

Third Parties

galaxefi requires that all third parties acting on its behalf comply with this Anti-Corruption Policy. Appropriate due diligence must be conducted before engaging with any third party to ensure they have a commitment to anti-corruption principles.

Reporting and Compliance

Employees and third parties are required to report any suspected or actual violations of this policy to their supervisor or through the galaxefi‘s confidential reporting mechanism. galaxefi will investigate all reports and take appropriate action, which may include disciplinary measures or termination of contracts.

Training and Awareness

galaxefi will provide regular training and resources to ensure all employees and relevant third parties understand and comply with this Anti-Corruption Policy.

Policy Review and Updates

The Legal and Compliance Department is responsible for monitoring the implementation of this policy and conducting regular reviews to ensure its effectiveness. This policy will be reviewed and updated periodically to reflect any changes in applicable laws and regulations.

Quick Contact

Being our active vendor, it is expected that you agree to comply with this policy. For questions or concerns about this Policy, please use the following form: