Last updated: 9 March 2025
Venti (“we,” “us,” or “our”) has a zero-tolerance policy toward bribery and corruption. This Anti-Corruption Policy applies to all employees, directors, contractors, agents, and any other persons or entities acting on our behalf in any jurisdiction. It supplements our Code of Conduct.
We are committed to complying with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and the laws of every country in which we operate or do business. This policy is designed to prevent bribery and corruption and to ensure that we act with integrity in all our business relationships.
Bribe means any financial or other advantage offered, promised, given, requested, or accepted to induce or reward improper performance, or that would be improper if performed. It includes cash, gifts, hospitality, employment, contracts, or any other benefit.
Government official includes any officer or employee of a government, a public international organisation, a political party, or a political party official, or any person acting in an official capacity for any of the above. It also includes employees of state-owned or state-controlled enterprises where applicable under local law.
Facilitation payment means a small payment made to secure or expedite a routine governmental action (e.g. processing a permit or document). Regardless of size or local custom, facilitation payments are prohibited under this policy. If you are asked for such a payment, you must decline and report it in accordance with Section 7.
We do not offer, promise, give, request, accept, or authorize any bribe or other improper advantage—whether directly or through a third party—to or from any person (including government officials, customers, suppliers, or business partners) in order to:
This prohibition applies regardless of whether the bribe is paid or received by us or by someone else on our behalf. Facilitation payments are not permitted. If you are uncertain whether a payment or advantage is permitted, you must seek guidance and obtain approval before proceeding.
Reasonable, proportionate, and transparent gifts and hospitality may be acceptable where they are consistent with local law and our internal guidelines, do not create a conflict of interest, and could not be perceived as intended to influence a decision. All such gifts and hospitality must be properly documented and approved where required by our internal procedures.
We do not offer or accept gifts or hospitality involving government officials (beyond de minimis items permitted by law and our guidelines) without prior approval. We do not make charitable or political donations as a way to secure an improper business advantage. Any donations must comply with our internal approval and record-keeping requirements.
When in doubt, do not give or accept the gift or hospitality. Consult your manager or the contact in Section 8 before proceeding.
We may be held responsible for the actions of agents, distributors, consultants, and other third parties who act on our behalf. We therefore conduct appropriate due diligence before engaging such parties and ensure that our agreements with them require compliance with anti-corruption laws and this policy.
We do not engage or retain any third party where we know or have reason to believe that the third party will offer or pay bribes. We monitor relationships with third parties and take action if we become aware of conduct that violates this policy. Payments to third parties must be for legitimate services, properly documented, and consistent with fair market value.
We maintain accurate books, records, and accounts that fairly reflect our transactions and dispositions of assets. We do not maintain off-the-books accounts, slush funds, or other arrangements used to conceal improper payments. We do not make false, misleading, or incomplete entries in our records.
We maintain internal controls designed to prevent and detect bribery and corruption, including approval procedures for gifts, hospitality, and payments to third parties where appropriate. All expenses and payments must be properly documented and retained in accordance with our retention policies and applicable law.
We provide training on this policy and applicable anti-corruption laws to employees and relevant third parties as appropriate. We communicate this policy internally and make it available to business partners where relevant. Everyone covered by this policy is expected to complete required training and to apply this policy in their day-to-day work.
Anyone who becomes aware of a potential violation of this policy must report it promptly through the contact channel provided on our platform or in your account. Reports may be made anonymously where permitted by local law and our procedures. We do not tolerate retaliation against anyone who reports in good faith or who participates in an investigation.
We will investigate reported concerns in good faith and take appropriate action, which may include disciplinary measures, termination of business relationships, and reporting to law enforcement or regulators where required or appropriate. We will maintain confidentiality to the extent consistent with a thorough investigation and our legal obligations.
For questions about this Anti-Corruption Policy, for guidance on a specific situation, or to report a concern, contact us through the contact information provided on our platform or in your account. We will respond in accordance with our internal procedures and applicable law.