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Anti-Bribery & Corruption Policy

Aevum Zenth Conglomerate maintains a zero-tolerance stance against bribery, corruption, and illicit facilitation in all operations worldwide.

Effective: Jan 1, 2026
Last Reviewed: Dec 15, 2025
Version 4.2

Our Commitment

Aevum Zenth Conglomerate and its 400 subsidiaries are committed to conducting business with integrity, transparency, and compliance with all applicable anti-bribery and anti-corruption laws globally. This includes the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other relevant jurisdictions.

Zero Tolerance

Bribery and corruption are strictly prohibited in all forms. Violations will result in immediate disciplinary action, up to and including termination and legal prosecution, regardless of seniority or business criticality.

This policy applies to all employees, directors, officers, agents, contractors, consultants, joint venture partners, and any third parties acting on behalf of Aevum Zenth.

Scope & Application

This policy governs all interactions with government officials, state-owned entities, private sector actors, and non-governmental organizations. It covers:

  • All 400 subsidiaries and divisions across 62 countries
  • Business development, procurement, and sales activities
  • Interactions with public officials at all levels (local, regional, national, international)
  • Third-party intermediaries and agents
  • Philanthropy, political contributions, and lobbying activities

Key Definitions

Bribery

The offering, promising, giving, receiving, or soliciting of any undue advantage to influence the actions of an individual in the discharge of their official or business duties.

Corruption

Abuse of entrusted power for private gain, including extortion, embezzlement, nepotism, and conflict of interest.

Public Official

Any individual acting on behalf of a state or public body, including employees of state-owned enterprises, political party officials, and candidates.

Facilitation Payment

A small, unofficial payment made to secure or expedite routine, non-discretionary actions by a government official. Prohibited under this policy.

Prohibited Conduct

The following actions are strictly prohibited:

  • Offering or providing money, gifts, favors, or anything of value to influence decisions or obtain improper advantage
  • Making off-book payments or maintaining slush funds
  • Providing false or misleading information to evade anti-bribery controls
  • Extorting or coercing others into paying bribes
  • Engaging in retaliation against whistleblowers
High-Risk Transactions

Any transaction involving government contracts, customs clearance, licensing approvals, or interactions with high-risk jurisdictions requires pre-approval from the Chief Compliance Officer.

Gifts & Hospitality

General Principles

Gifts and hospitality must be modest, lawful, transparent, and genuinely offered in the spirit of goodwill. They must never be intended to influence a decision or create an obligation.

Thresholds & Approvals

Value Requirement Approval Authority
Under $50 Permitted with documentation Department Head
$50 – $200 Requires pre-approval Business Unit Leader
$200 – $500 Strict scrutiny required Chief Compliance Officer
Over $500 Prohibited N/A

All gifts to or from public officials must be recorded in the centralized Gifts Register within 48 hours.

Facilitation Payments

Aevum Zenth prohibits facilitation payments in all circumstances, regardless of local customs or industry norms. If you are asked to make such a payment:

  1. Politely decline and cite company policy
  2. Document the request immediately
  3. Report the incident to Compliance within 24 hours
  4. Escalate to legal counsel if coercion or threats occur

Record Keeping

All business transactions must be accurately recorded in Aevum Zenth's books and records. Prohibited practices include:

  • Maintaining off-book accounts or slush funds
  • Recording expenses as something they are not
  • Falsifying invoices or receipts
  • Destroying documents to conceal improper payments

Third-Party Due Diligence

Aevum Zenth is responsible for the actions of third parties acting on its behalf. All agents, consultants, distributors, and joint venture partners must undergo due diligence proportional to risk before engagement.

Contracts with third parties must include anti-bribery representations, warranties, and audit rights.

Reporting & Protection

If you suspect or witness a violation of this policy, you are obligated to report it immediately. Multiple confidential channels are available:

  • Aevum Zenth Ethics Hotline: 1-800-AEVUM-ZC (24/7, multilingual)
  • Online Portal: secure report form
  • Direct Email: compliance@aevumzenth.internal
Anti-Retaliation

Aevum Zenth strictly prohibits retaliation against any individual who reports concerns in good faith. Retaliation will be treated as a separate policy violation and may result in termination.

Consequences

Violations of this policy will result in:

  • Disciplinary action up to and including termination
  • Civil and criminal prosecution where applicable
  • Recovery of any improperly obtained benefits
  • Exclusion from future contracts and partnerships

Have Questions or Concerns?

Our Compliance team is available to assist you with policy guidance, training, and reporting.

Report a Violation Contact Compliance

Policy Updates

This policy is reviewed annually and updated as needed to reflect changes in law, regulations, and business practices. All employees must acknowledge receipt and understanding of this policy through the Aevum Zenth Learning Management System.

Policy Owner: Office of the Chief Compliance Officer
Governing Body: Board of Directors – Risk & Compliance Committee