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Anti-Corruption and Anti-Bribery Statement

PointWire > Anti-Corruption and Anti-Bribery Statement

Introduction

PointWire Holdings Limited and its subsidiaries (collectively, “PointWire“) are committed to promoting the highest standards of ethical business conduct and ensuring compliance with all applicable laws, rules, and regulations.  As part of this commitment, PointWire expects all employees, consultants, partners, distributors, resellers, and other agents of PointWire (collectively, “Representatives”) to comply with the Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act, other anti-bribery laws, local laws, this policy, and any procedures developed by management to implement this policy.

Who Are We? 

We are PointWire Holdings Limited. Our registered address is 23 Algitha Road, Skegness, United Kingdom, PE25 2AG. You can contact us by post at the above address, by email at  contact@pointwire.co.uk or by telephone on +44 1223 455185. 

Prohibited Conduct 

PointWire employees and all Representatives are prohibited from, directly or indirectly, paying, authorising, making, offering, promising, requesting, receiving or accepting money or Anything of value to or from a Government official or other individual or entity for an Improper purpose.  This prohibition includes more than just obvious bribes and kickbacks.

Any doubts about whether a particular person is a Government official should be resolved by assuming that the individual involved is a Government official for purposes of this policy.

“Anything of value” includes money and monetary equivalents (such as gambling chips and gift cards), entertainment, accommodations, gifts and any other benefit. No minimum or threshold amount constitutes a bribe – anything of value, whatever the amount, is sufficient to trigger a violation of this policy.

How PointWire will deal with suspicious activities
If we suspect fraudulent or corruptive behaviours or if an issue is raised to us regarding the behaviour outlined in this statement, we will:

  • Take any complaint or notification seriously and it will not be ignored.
  • Handle the complaint or notification fairly and sensitively.
  • Investigate the situation thoroughly and as quickly as possible.
  • Assess the risks arising from the parties continuing to work together while the concern is being addressed and consider alterations to working arrangements that would support this.
  • Create an environment where PointWire Representatives are clear that fraud, corruption, and bribery is unacceptable.
  • Any PointWire Representative suspected of fraud or corruption will be presumed innocent until proven otherwise.
  • The responsibility for the investigation of staff will be completely entrusted to a fraud specialist as soon as it becomes evident that criminal activity may be involved.
  • Respond constructively and supportively where a cause for concern about a PointWire Representative is raised regarding fraud, corruption, and bribery behaviours or is accused of such behaviours.
  • If necessary, any fraudulent activity may be reported to relevant law enforcement agencies.
Risk Management

PointWire have a zero-tolerance approach to fraud and corruption, and we are committed to providing a safe working environment for our Representatives. To reduce the risk of fraud, corruption, and bribery, PointWire:

  • Conducts regular risk assessments for these behaviours, in accordance with PointWire’s ISO27001 compliance.
  • Have the appropriate company policies in place, including an “Anti-Bribery, Anti-Corruption and Anti-Fraud Internal Policy”
  • Conduct background checks on all PointWire Representatives during onboarding.
  • Have a clearly defined reporting procedure.
  • Most importantly, PointWire encourages all Representatives to follow their company values, which includes, but is not limited to, conducting all business actions with Integrity and nobility. More details of PointWire’s values can be found here:  Our Values – PointWire
This statement is reviewed on an annual basis by the directors at PointWire Holdings Limited and it’s subsidiaries and updated if necessary.  Please send any questions about PointWire Holdings Limited’s statement from above to contact@pointwire.co.uk.