Wayland LLC, Inform Wayland DOO, and Inform Innovation Inc. (“Wayland”; the “Company”; “We”) demands the highest standards of integrity and ethical conduct in its business dealings. We will not tolerate any bribery or corrupt practices related to our business activities from our employees or business partners. We are committed to transparent reporting and to taking all other reasonable measures which avoid Wayland’s involvement in bribery or corruption.
Bribery and corruption undermine the rule of law and the principle of fair competition. Such activities entrench bad governance, hindering efforts to alleviate poverty and often contributing to economic instability and human rights abuses. Whilst the risk of bribery exists in all geographies, sectors and transactions, Wayland understands that steps can be taken to mitigate the inherent risk of corrupt behavior. This Anti-Bribery and Anti-Corruption Policy (the “Policy”) aims to inform Wayland management, employees and business partners about our intention to closely monitor corruption risk and to take immediate action if evidence of corrupt activity is suspected.
The objective of this Policy is to provide a procedure by which Wayland and its subsidiaries conducts its business, ensuring honest and ethical business practices which reflect the highest standards of integrity and in compliance with all applicable laws and regulations.
This Policy applies to all Wayland employees, contract staff or business partners working on our behalf (“Wayland Employees”). Wayland Employees must never accept or give a bribe, facilitation payment, kickback or other improper payment under any circumstances.
This includes transactions with:
Wayland’s management takes responsibility for encouraging a transparent and ethical culture at Wayland. Their role includes:
Wayland prohibits the following behavior from Wayland Employees:
Wayland strictly prohibits the use of improper payments. This includes:
For the avoidance of doubt this includes:
To directly or indirectly offer, give or agree to give or offer a loan, reward, advantage or benefit of any kind to a public official, political party, party official or political candidate as consideration for an act or omission by the recipient in connection with the performance of the recipients duties or functions with the government. Examples include applications for environmental permits, customs procedures or judicial proceedings.
To induce an official to use his or her position to influence any acts or decisions of government for the purposes of obtaining an advantage in the course of business; or to agree, or comply, with any demands for a bribe made by a public official.
Wayland recognizes that reasonable and proportionate gifts and hospitality are a legitimate contribution to good business relationships between Wayland and its business partners. However, judgement must be used to ensure these are reasonable and ethical.
When selecting potential business partners, Wayland endeavors to work with those that are likeminded in their approach to maintaining high ethical standards as well as demonstrated legal and regulatory compliance. Wayland will include risk management measures in its procurement practices, for example:
Once the business relationship is successfully approved, periodical review of the business relationships will be ongoing, although the level of oversight required will vary depending on the risks identified upon initial assessment.
A copy of this Policy has or will be made available to all Wayland Employees as well as its auditors, legal counsel and other advisors. It is also posted on the website at https://wayland.io
Wayland will provide periodic compliance training on this Policy and good practices. The aims of the training are:
Wayland Employees that become aware of actions which could constitute a violation of this Policy are required to report it to their immediate supervisor. However, if the Wayland Employee is not comfortable reporting the matter to their immediate supervisor, or does not feel their immediate supervisor has taken sufficient action, they are encouraged to report the matter to the Compliance Officer ([email protected]).
No Wayland Employee will suffer undue consequences for:
Any Wayland Employee who is found to be giving or taking bribes or partaking in any other corrupt acts will be subject to disciplinary action which may ultimately lead to dismissal. The violation of this Policy may also be a violation of certain laws and, if appropriate, Wayland may refer the matter to the appropriate regulatory authorities which could lead to criminal proceedings.
Should evidence of corrupt practices be uncovered, Wayland will consider a full range of remedial measures including but not limited to:
This policy will be reviewed and evaluated regularly by the Board of Directors and the Management. The review will consider:
Should you have any concerns or queries regarding this policy or believe that you may have become aware of any breach thereof, you are encouraged to contact the company compliance officer or the Chief Executive Officer, James Anderson.