OIO Group refers to OIO Holdings Limited and its subsidiaries.

1.   Policy

Zero tolerance approach

1.1   OIO Group adopts a zero tolerance approach to bribery and corruption of any form as reflected in this Anti-Bribery and Corruption Policy (“this Policy”).

1.2   We do not offer or pay or accept any bribes for any purpose whether directly or through a third party. This applies to domestic and foreign governments, as well as to a private party (sometimes called commercial bribery).

1.3   We must at all times comply with the this Policy and all relevant anti-bribery and corruption laws including the Singapore Prevention of Corruption Act, the UK Bribery Act, the US Foreign Corrupt Practices Act, the Australian Criminal Code Act and other similar anti- bribery laws where we do business.

1.4   This Policy is to be read in conjunction with other related policies of OIO Group.

2.   Bribery or corruption

2.1   A bribe or corrupt action includes the receiving, offering, promising, authorizing or providing “anything of value” to any customer, business partner, vendor or other third party in order to secure, induce or keep an improper or unfair advantage.

2.2   Anything of value is not only cash, and includes (but not limited to) cash equivalents like gifts, services, employment offers, loans, travel and entertainment, charitable donations, sponsorships, business opportunities, favourable contracts or giving anything even if nominal in value.

2.3   There is a presumption of corrupt intent if anything of value is given to employees of, or persons dealing with, the government under Singapore laws.

2.4   Facilitation payments are strictly prohibited. These are routine payments made in some countries to government officials to expedite or secure routine governmental action.

3.   Compliance

3.1   All employees and board of directors of OIO Group, and all third parties who represent us, or who are our suppliers, contractors or other business partners are required to comply with this this Policy, and not engage in any form of bribery or corruption. 

3.2   You must as employees:

a)  Not give or offer to give or authorize to give anything of value that could be considered to be a bribe

b)  Not request or accept or authorise the request or acceptance of, directly or indirectly, anything of value that could be considered to be a bribe

c)  Know what this Policy means and comply with it

d)  Report as soon as possible any suspected breaches of this Policy to Head of Finance and Administration of OIO Group, without risk of reprisal.

3.3   You must as business leads or function heads ensure that:

a)   All employees in your sector, function or line of business are aware of the need to comply with the this Policy, and receive regular messages from the line management reminding them to comply

b)   Any non-compliance to the this policy in your sector, function or line of business is referred to Head of Finance and Administration of OIO Group, without risk of reprisal

c)   All records are accurate, complete and accessible for review, including records relating to commissions, travel and entertainment.

3.4   Specific guidance on common forms of bribery:

• Charitable contributions: You must not use charitable contributions as a way of concealing a bribe.
• Political contributions: You must not use OIO Group’s resources including funds or facilities to provide support for, or contribute to any political organisation.

4.   Consequences of violation

A violation of this this Policy will lead to disciplinary action for the individuals involved up to and including dismissal, and reporting to the police or relevant regulatory agency. Additionally the OIO Group may also be exposed to criminal or civil claims and reputational harm arising from the violation.

5.   Working with Third Parties

We do not condone the action of, nor do we wish to be held liable for, any of our third parties who may have made any bribes whilst acting for us, whether with or without our knowledge. Accordingly it is very important that the requisite and proper due diligence of all third parties representing us or providing services to us, are undertaken before we engage such third parties. These third parties should also undertake not to engage in any form of bribery or corruption.

6.   Monitor and Review

This Policy will be regularly reviewed and updated as needed to ensure it continues to be adequate and effective.

7.   Questions

Any questions in relation to this Policy should be referred to Head of Finance and Administration of OIO Group.