Anti-Bribery Policy




1. Introduction


Hubsec Solutions is committed to conducting its business with the highest standards of integrity, honesty, and transparency. This Anti-Bribery Policy outlines our zero-tolerance approach towards bribery and corruption in all aspects of our operations. The purpose of this policy is to provide clear guidelines and expectations to all employees, contractors, and stakeholders on preventing and combating bribery.


2. Scope


This policy applies to all individuals associated with Hubsec Solutions, including but not limited to employees, directors, officers, contractors, agents, consultants, and business partners. It covers all activities and operations, both within South Africa and internationally, conducted on behalf of Hubsec Solutions.


3. Definitions


a) Bribery: The offering, giving, receiving, or soliciting of anything of value with the intent to influence an individual’s actions, decisions, or behaviour in a position of trust, or to gain an improper advantage.


b) Facilitation Payment: A small payment made to expedite routine actions or services that a person is already obligated to perform.



4. Prohibition of Bribery


4.1. Hubsec Solutions prohibits any form of bribery, whether direct or indirect, in all business dealings, including interactions with government officials, clients, suppliers, and other third parties.


4.2. No employee or stakeholder shall offer, promise, authorize, or provide any improper payment, gift, favour, or benefit to any individual or organization to gain an unfair advantage, secure business, or influence business decisions.


4.3. No employee or stakeholder shall accept, request, or receive any bribe, kickback, or other improper payment or benefit, either personally or on behalf of Hubsec Solutions.



5. Gifts, Hospitality, and Entertainment


5.1. Hubsec Solutions recognizes that the exchange of customary gifts, hospitality, and entertainment is a common business practice. However, these exchanges must be transparent, reasonable, and comply with applicable laws and regulations.


5.2. Gifts, hospitality, or entertainment offered or received must not be lavish, excessive, or intended to improperly influence business decisions. They should be of nominal value, appropriate to the business context, and must not create a perception of undue influence or impropriety.


5.3. Approval from the appropriate authority should be sought for any gifts, hospitality, or entertainment exceeding a predetermined threshold set by Hubsec Solutions.



6. Relationships with Government Officials and Public Representatives


6.1. Special attention must be given to interactions with government officials and public representatives due to the heightened corruption risks associated with these relationships.


6.2. No employee or stakeholder shall offer, promise, or provide any improper payment, gift, or benefit to a government official or public representative to influence or secure an advantage in business dealings.


6.3. All interactions with government officials and public representatives must comply with applicable laws, regulations, and company policies. Prior approval must be obtained for any engagements involving government officials.



7. Facilitation Payments


7.1. Hubsec Solutions strictly prohibits facilitation payments, regardless of the prevailing customs or practices in any jurisdiction. Employees and stakeholders must not make or accept facilitation payments.


7.2. If an individual is asked for a facilitation payment, they should politely decline and report the incident to their supervisor or the designated compliance officer.



8. Due Diligence on Third Parties


8.1. Hubsec Solutions conducts thorough due diligence on all third parties, including suppliers, agents, consultants, and business partners, to assess their integrity, reputation, and compliance with anti-bribery laws and regulations.


8.2. Before engaging in a business relationship with a third party, appropriate due diligence must be conducted, and contracts or agreements should include anti-bribery and corruption clauses.



9. Reporting and Whistle-blowing


9.1. Hubsec Solutions encourages all employees and stakeholders to report any suspected or actual incidents of bribery, corruption, or related misconduct. Reporting can be done through the designated reporting channels, such as the company’s whistle-blower hotline or reporting email address.


9.2. Whistle blowers will be protected from retaliation, and their identity will be kept confidential to the extent permitted by law. Any form of retaliation against whistle blowers is strictly prohibited and will result in disciplinary action.


9.3. All reports will be promptly and thoroughly investigated by the appropriate internal departments or external authorities, as necessary. Investigations will be conducted with confidentiality, objectivity, and fairness.



10. Compliance Monitoring and Enforcement


10.1. Hubsec Solutions is committed to monitoring compliance with this policy and implementing appropriate measures to prevent and detect bribery and corruption.


10.2. Regular assessments, internal audits, and reviews will be conducted to evaluate the effectiveness of anti-bribery controls, identify areas of improvement, and address any compliance gaps.


10.3. Non-compliance with this policy may result in disciplinary action, including termination of employment, contract termination, legal action, or any other appropriate measures as determined by Hubsec Solutions.



11. Training and Awareness


11.1. Hubsec Solutions will provide comprehensive anti-bribery and corruption training to all employees and stakeholders, raising awareness of the risks associated with bribery and corruption, and ensuring understanding of this policy and related procedures.


11.2. Training programs will be regularly updated to reflect changes in laws, regulations, and best practices, and will cover specific bribery and corruption risks relevant to employees’ roles and responsibilities.



12. Policy Review


12.1. This Anti-Bribery Policy will be periodically reviewed to ensure its relevance, effectiveness, and alignment with changing legal requirements and industry standards.


12.2. Any updates or revisions to this policy will be communicated to all employees and stakeholders, and appropriate training will be provided to ensure understanding and compliance.


12.3. Employees and stakeholders are encouraged to provide feedback and suggestions for improving this policy and the overall anti-bribery and corruption framework of Hubsec Solutions.




Hubsec Solutions is committed to conducting business ethically and in compliance with anti-bribery and corruption laws. Every employee and stakeholder have a responsibility to prevent and combat bribery and corruption. By adhering to this policy and reporting any concerns, we contribute to maintaining a culture of integrity, transparency, and accountability within the organization and in all our business dealings.