Anti-Bribery & Anti-Corruption

1. Purpose

Capital Contracts takes a zero-tolerance approach to bribery, corruption, facilitation payments, improper advantages and unethical business conduct. This policy sets out our expectations for business integrity across all jurisdictions where Capital Contracts operates or supports clients.

Capital Contracts's work may involve public and private sector projects, procurement, tendering, contract administration, claims, negotiations and dispute support. These environments can create corruption risk. Our position is simple: Capital Contracts does not offer, pay, request, receive or facilitate bribes.

2. Scope

This policy applies to Capital Contracts directors, employees, consultants, representatives, subcontracted advisers, intermediaries and anyone acting on behalf of Capital Contracts.

3. Prohibited Conduct

Capital Contracts prohibits:

• offering, promising, giving, requesting or accepting bribes;
• facilitation payments;
• kickbacks or secret commissions;
• improper gifts, hospitality or entertainment;
• payments to influence tender outcomes, claims, approvals, permits, inspections, certificates or payments;
• using consultants, agents or intermediaries to do anything Capital Contracts could not do directly;
• falsifying records to conceal improper payments;
• retaliating against anyone who refuses to engage in bribery or reports a concern.

4. Public Officials and Private-Sector Bribery

Bribery risk may involve public officials, state-owned companies, private clients, contractors, consultants, suppliers or project personnel. A public official may include government employees, employees of state-owned enterprises, authority representatives, permitting officers, customs officials, judges, arbitrators, police, military personnel, political party officials or candidates for office.

Private-sector bribery is also prohibited. Improper payments or advantages offered to commercial counterparties are not acceptable simply because no public official is involved.

5. Facilitation Payments

Facilitation payments are small unofficial payments made to speed up or secure routine actions, such as processing documents, permits, customs clearance or access. Capital Contracts prohibits facilitation payments, even where they may be locally common.

If a payment is demanded under threat to personal safety, the person should prioritise safety, report the incident as soon as possible and record the circumstances accurately.

6. Gifts and Hospitality

Reasonable business hospitality may be acceptable where it is modest, transparent, lawful, proportionate, infrequent and not intended to influence a decision. Gifts or hospitality are not acceptable where they could create a sense of obligation, influence a tender, claim, payment, certification, procurement decision or dispute outcome, or appear improper.

Cash, cash equivalents, personal benefits, lavish travel, hidden hospitality or gifts to family members are not acceptable.

7. Political and Charitable Contributions

Capital Contracts does not make political contributions for the purpose of obtaining business advantage. Charitable contributions, sponsorships or community support must not be used as a route for bribery or improper influence.

8. Third Parties and Intermediaries

Agents, consultants, local representatives and other intermediaries can create bribery risk. Capital Contracts expects appropriate due diligence before engaging third parties, particularly where they interact with public officials, procurement bodies, project owners or decision-makers.

Red flags include:

• requests for unusually high commissions;
• vague scope of services;
• requests for payment to offshore or unrelated accounts;
• refusal to provide documentation;
• close undisclosed links to decision-makers;
• pressure to proceed without due diligence;
• success fees tied to permits, tenders or claims outcomes without clear legitimate basis.

9. Accurate Books and Records

Capital Contracts records must accurately reflect transactions, expenses, invoices and business activities. False descriptions, hidden payments, split invoices or misleading expense claims are prohibited.

10. Reporting Concerns

Any bribery or corruption concern should be reported promptly to Capital Contracts management. Capital Contracts will review concerns and take proportionate action. No person will be penalised for refusing to pay a bribe or for raising a concern in good faith.

11. International Standard Context

This policy is informed by international anti-corruption principles, including the OECD Anti-Bribery Convention and the UN Global Compact principle that businesses should work against corruption in all its forms, including extortion and bribery.