1. Policy Statement

Hyperspan does not participate in bribery or corruption in any form. We will not offer, promise, give, request, agree to receive, or accept any bribe, inducement, kickback, improper payment, or other advantage intended to influence a business decision improperly.

We are committed to complying with all applicable anti-bribery and anti-corruption laws and regulations in every country and market in which we operate.

2. Scope

This policy applies to:

• all directors, officers, and employees of Hyperspan;
• temporary workers, contractors, and consultants;
• agents, intermediaries, and advisers acting on our behalf;
• suppliers, distributors, resellers, and commercial partners where relevant;
• any person or organisation representing Hyperspan in a commercial or project-related capacity.

3. Prohibited Conduct

The following conduct is strictly prohibited:

1. Offering or giving money, gifts, hospitality, favours, commissions, or anything of value to obtain or retain business improperly.
2. Requesting or accepting any payment, reward, gift, or benefit that could influence business judgement or create an improper obligation.
3. Making facilitation payments, unofficial payments, or “speed payments” to secure routine actions or approvals.
4. Using third parties to do anything that Hyperspan would not be permitted to do directly.
5. Creating false records, misleading invoices, off-book accounts, or disguised payments.
6. Using charitable contributions, sponsorships, rebates, discounts, or marketing support as a cover for improper influence.

4. Gifts, Hospitality & Donations

Hyperspan recognises that reasonable and proportionate gifts, hospitality, and legitimate promotional activity can form part of normal business relationships. However, they must never be used to influence a decision improperly or create the appearance of impropriety.

Any gifts, hospitality, donations, or sponsorships must follow internal approval rules where applicable and must be capable of withstanding public and regulatory scrutiny.

5. Responsibilities

• All personnel must read, understand, and comply with this policy.
• Managers must promote ethical conduct and ensure that business activity under their control is carried out responsibly.
• Anyone acting for or on behalf of Hyperspan must avoid situations that could create an improper conflict of interest or bribery risk.
• Accurate books, records, approvals, and supporting documentation must be maintained for all transactions.

6. Reporting Concerns

Any employee, contractor, supplier, or third party who becomes aware of conduct that may breach this policy should report it promptly.

Reports may include concerns about suspicious payments, unusual commissions, undocumented discounts, improper gifts or hospitality, third-party behaviour, conflicts of interest, or requests for unofficial payments.

Hyperspan will treat genuine reports seriously and aims to ensure that concerns raised in good faith are handled fairly and without retaliation.

7. Third Parties

Bribery risks can arise through third parties as well as direct dealings. Hyperspan expects suppliers, agents, distributors, consultants, and other business partners to act lawfully and ethically.

1. Appropriate checks may be carried out before appointing or engaging third parties.
2. Commercial arrangements should be clearly documented and commercially justifiable.
3. Payments must be proportionate, properly approved, and supported by legitimate invoices and records.
4. We reserve the right to decline, suspend, or end relationships where bribery or corruption concerns arise.

8. Compliance & Monitoring

Hyperspan is committed to maintaining processes designed to prevent bribery and corruption from taking place within the business. These may include policy communication, approval procedures, record-keeping controls, due diligence, commercial oversight, and periodic review.

This policy may be updated from time to time to reflect changes in law, regulation, business operations, or best practice.

9. Breaches

Any breach of this policy may result in disciplinary action, suspension, termination of contract, removal from approved supplier or partner status, and where appropriate, referral to law enforcement or regulatory authorities.

10. Contact

Questions about this policy, or any report relating to suspected bribery or corruption, should be directed to Hyperspan using the contact details below.

Last updated: [Insert date]