Anti-Corruption and Bribery Policy

Policy Statement

Spicy Minds Ltd (Trading as Rowan) is committed to conducting its business ethically and legally. We have zero tolerance for corruption and bribery in any form. This policy outlines our stance on preventing, identifying, and addressing bribery and corrupt practices in all areas of our operations.

Scope

This policy applies to all employees, officers, agents, consultants, and contractors of Spicy Minds Ltd, as well as any other persons or entities doing business with us.

Prohibition of Bribery and Corruption

Illegal bribes, kickbacks, and other forms of corruption are strictly prohibited.

This prohibition extends to indirect contributions or payments made through intermediaries.

Responsibilities

Directors: Ensure all employees and business partners are aware of and comply with this policy.

Employees: Required to comply with all anti-corruption laws and report any suspected bribery or corruption.

Compliance Officer: Oversee the implementation of this policy, training, and response to violations.

Gifts and Hospitality

Offering or accepting reasonable and appropriate gifts or hospitality is permitted, provided it complies with law and is not intended to influence decision-making processes.

All gifts and hospitality should be transparent and properly recorded.

Training and Communication

Providing training to all employees on anti-corruption practices and the implications of bribery.

Regular communication to reinforce this policy and its importance.

Reporting and Whistleblowing

Encouragement of reporting any suspected bribery or corruption without fear of retaliation.

Maintaining channels for confidential reporting.

Compliance and Monitoring

Regular auditing and monitoring to ensure compliance with this policy.

Appropriate disciplinary action for policy violations, up to and including termination of employment or contracts.

This policy will be reviewed and updated regularly to reflect new legal and regulatory developments and ensure good practice.

Date of Last Review: 18 Jan 2024