1. Position
Veltrion does not pay bribes, does not accept bribes, and does not make
facilitation payments. This applies without exception, in every market, including where a
payment is customary, expected, small, or would speed up a routine process.
This matters more than usual in our work. Regulatory submissions, tender processes, public-sector
listing and customs clearance are precisely the situations in which improper payments are solicited.
2. Who this applies to
This policy applies to Veltrion's directors and personnel, and to contracted delivery partners,
agents, distributors and any third party acting for or on behalf of Veltrion in connection with a
mandate.
3. Laws we work to
- Prevention and Combating of Corrupt Activities Act 12 of 2004 (South Africa), which criminalises corrupt activities in both the public and private sectors and imposes a duty to report certain offences.
- UK Bribery Act 2010 and the US Foreign Corrupt Practices Act, both of which have extraterritorial reach and commonly bind our clients and, through them, their suppliers.
- Applicable anti-corruption law in each market in which work is performed.
Where standards differ, we apply the stricter one.
4. What is prohibited
- Offering, giving, requesting or accepting anything of value to improperly influence a decision, including a regulatory decision, a tender award or a listing.
- Facilitation payments, meaning small unofficial payments to secure or speed up a routine action to which one is already entitled.
- Using an intermediary, partner or agent to do indirectly what this policy prohibits directly.
- Political contributions made on behalf of Veltrion.
- Charitable donations, sponsorships or hospitality used as a route to improper influence.
5. Gifts and hospitality
Modest, infrequent, transparent business hospitality is permitted where it is proportionate, properly
recorded, lawful in the relevant market, and would not embarrass either party if made public.
Anything offered to or received from a public official or healthcare professional
receives heightened scrutiny, given the sector we operate in. Cash and cash equivalents are never
acceptable.
6. Third parties and delivery partners
Because our model depends on contracted partners in market, third-party conduct is our principal
exposure. Accordingly:
- partners are screened for anti-corruption risk before engagement;
- written terms include anti-bribery obligations and a right to terminate for breach;
- payments are made against a defined scope and a proper invoice, to a bank account in the partner's own name, never to a third-party or personal account on request;
- success fees contingent on a regulatory approval are not used, because they create precisely the wrong incentive.
7. Books and records
All payments are recorded accurately and in reasonable detail. No undisclosed or unrecorded account,
fund or asset is established for any purpose.
8. Raising a concern
Any person who is offered a bribe, asked to make one, or suspects that one has occurred, must report
it. See Speak Up and Protected Disclosures. Reporting in good faith
carries no adverse consequence, including where the suspicion turns out to be mistaken.
Losing work is an acceptable outcome. If a mandate, a market or a
tender can only be obtained by an improper payment, Veltrion will not pursue it, and no member of
personnel will be criticised for the loss.
Questions about this document should be directed to
info@veltrionlaboratories.com,
marked for the attention of the Information Officer.