Introduction

VIVA is committed to conducting all business in accordance with the highest ethical standards and to strictly rejecting all forms of corruption and bribery. This Anti-Corruption Policy serves to reaffirm our company’s commitment to avoiding corrupt practices and to provide guidelines and procedures to ensure compliance with all applicable anti-corruption laws.

Scope

This policy applies to all employees, directors, officers, contractors and consultants of [Company Name] worldwide. It covers all business activities and operations involving our employees and related parties.

Definitions

Corruption: The misuse of entrusted power for private gain.

Bribery: Offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust.

Policy Guidelines

Prohibition of Bribery and Corruption: VIVA strictly prohibits any form of bribery and corruption. Employees and associated third parties are not permitted to, directly or indirectly, offer, promise, give, or accept bribes to or from any person or organization. This includes government officials, clients, contractors, and individuals in the private sector.

Gifts and Hospitality: Gifts and hospitality may be offered or accepted only when they are reasonable, appropriate, and justifiable under the circumstances. They must not be intended to influence an individual’s impartiality or decision-making process. All gifts and hospitality must be transparently recorded in the company’s gift registry.

Due Diligence: VIVA will conduct due diligence on third parties before entering into any agreements to ensure alignment with this Anti-Corruption Policy. Ongoing monitoring will be conducted to ensure compliance.

Training and Communication: Regular training on this policy and related legal requirements will be provided to all employees. This policy will be communicated to all third parties engaged with VIVA to ensure awareness and compliance.

Reporting Violations

Employees and external parties are encouraged to report any suspicious activities or breaches of this policy confidentially. VIVA ensures that all reports will be investigated thoroughly and promptly, with respect for the confidentiality and protection of those reporting.

Enforcement

Violations of this Anti-Corruption Policy will result in disciplinary action, up to and including termination of employment. Legal proceedings may also be initiated where applicable. Managers and supervisors are responsible for enforcing this policy and ensuring that employees under their supervision are aware of and comply with it.

Review and Modification

This policy will be reviewed annually and modified as necessary to ensure it meets legal requirements and aligns with best practices in corporate governance.

Conclusion

VIVA is dedicated to upholding the highest standards of honesty and integrity. We are committed to fighting corruption in all forms and maintaining a clean and ethical business environment.

Approval

This policy has been approved by Peter Hannon and is effective as of January 1, 2023.