Code of Ethics

Anti-Bribery and Anti-Corruption Policy

Introduction

Asire Consulting LLP (“Asire”) is committed to the setting up, utmost standards for transparency and accountability in all its affairs. Asire strives in attaining it’s mission through compliance of high legal and ethical standards. Asire does not tolerate any form of bribery, embezzlements or corruption, and will uphold all laws countering bribery, fraud and corruption in all forms.

Purpose

The purpose of this policy is to set out the responsibilities of Asire and those individuals acting on its behalf in observing and upholding Asire’s position on bribery and corruption. Every individual or group of individuals, associated to Asire in any form, whether the staff members, the ad-hoc staff engaged in the program activities of the organization, the consultants, the contractors, the interns, the partner organisations and any other party with a financial or trustee-beneficiary relationship with Asire are expected to share this commitment. The basic objective of this statement is setting out the policy of Asire towards the prevention and identification of bribery and corruption and the certain procedures to be followed, if at all, any fraud is found or having an idea / impression of it’s existence.

Scope

This policy applies to the Staffs, ad-hoc staffs, Advisers, Consultants, Suppliers, Partners and Individuals acting on behalf of the Firm, irrespective of their location.

Statement

Prohibited Activities

  1. Not to offer, promise or make any bribe or unauthorised payment or inducement ofany kind to anyone;
  2. Not to solicit business by offering, promising or making any bribe or unofficial payment to suppliers.
  3. Not to request or accept any kind of bribe or unusual payment or inducement that would not be authorised by Asire in the ordinary course of business.
  4. To refuse any bribe or unusual payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation and to report any such offers.
  5. Not to make facilitation payments. These are payments used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal or other entitlement. Asire will not tolerate or condone such payments being made.
  6. To report any breaches of this policy’s principles or standards or of any associated

Criminal Offence (as defined in IPC)

  1. Offer a bribe.
  2. Accept a bribe.
  3. Fail to prevent a bribe (only applies to commercial organisations).

Gifts and Hospitality

Asire realises that giving and receiving of gifts and hospitality without any mala-fide intentions, or in other words, where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

Raising a Concern

These rules are based on the following principles:-

  1. The right of Asire to take appropriate disciplinary steps against any delinquent staff member, who acts in a manner conflicting with the code of conduct and prescribed rules / regulations.
  2. At the same time the rules also recognize the right of delinquent staff member to a fair hearing and applicable and just disciplinary action.
  3. The emphasis of disciplinary action is on prevention, justice and rehabilitation.

Review of this Policy

In the interests of maintaining best practice, the contents of this Anti-Fraud Policy will be reviewed by the management every two years or any other appropriate time frame.

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