Effective Date:  5th August 2021

1. purpose

Integrity is at the core of how we work at Lumenisity (Our “Company”).

This Policy covers the principles and requirements on Anti-Bribery and Anti-Corruption Laws. The purpose of this Policy is to publicly communicate our zero-tolerance position towards all forms of bribery and corruption and to ensure that all Employees, Business Partners and Third Parties in relation with our Company not only comply at all times with Anti-Bribery and Anti-Corruption Laws in the jurisdictions the Company operates, but also the spirit and intent of such legislation, and do not engage in any corrupt practice or behaviour. This Policy ultimately provides with a single reference and guide on its related matters. We expect our Business Partners to have processes in place to ensure that this Policy is complied with at all times when dealing with or acting on behalf of our Company.


2.1 This Policy and the obligation to conduct business with the highest standards of honesty, integrity, and fairness in accordance with all applicable laws, statutes, regulations, and codes relating to anti-bribery and anti-corruption including but not limited to the Bribery Act 2010, apply (without limitations) to:

(a) Any and all Employees including individuals, persons, directors, managers, officers, shareholders, advisers, agents, partners, trainees, volunteers, intermediaries, interns, seconded-staff, subsidiaries, and other representatives (including accounting legal advisers, financial advisers and consultants) of a Party and of a Party’s Associated Companies, acting for or on behalf of such Party (individually and collectively) and any person, individual or organisation, working for or on behalf of the Company at all levels and grades, whether permanent, fixed term or temporary, and wherever located;

(b) Any and all actual or potential Business Partners including buyers, contacts, customers,  clients, contractors, corporations and any other commercial organisation, distributors, intermediaries, joint-ventures, organisations, resellers, sponsors, subcontractors, suppliers, government officials (officer, director, employee of a governmental entity, agency, department, or other instrumentality whether administrative, executive, legislative, judicial, military, municipal and any person acting in an official capacity on behalf of a government or organisation above, a political party, as well as any party official or candidate for public office), public bodies, politicians and political party, and other representatives (including  their advisers, representatives and officials), and any government-owned or controlled entity or enterprise, or of a pubic international organisation, and any other person who has a business-to-business relationship with our Company or performs or will perform services (including marketing and selling, or facilitating the marketing and selling, of Company’s products and services, or obtaining any governmental authorisation related to Company’s operations) or supplies goods or services for or on behalf of the Company; and

(c) Any Third Parties (including its representatives) anywhere in the world that come into contact with the Company and/or with whom our Company has arrangements in place in relation to the purchase of our products and/or services and/or acting for or on behalf of our Company.


Anti-Bribery and Anti-Corruption Laws means Laws that prohibit bribery and corruption of domestic or foreign government officials or of parties in private or commercial transactions. The Laws relating to Bribery include but are not limited to the U.K. Bribery Act 2010, the U.S Foreign Corrupt Practises Act and any other applicable anti-corruption laws;

Associated Companies means a Party’s holding company and subsidiary companies and its holding company’s other subsidiary companies from time to time, ‘holding company’ and ‘subsidiary’ having the meanings given to them in section 1159 of the Companies Act 2006, or equivalent and in the case of our Company shall include its shareholder entities;

Associated Person has the meaning given in section 8 of the Bribery Act 2010 or equivalent;

Bribery: has the meaning given to in section 1, 2, 6 ,7, of the Bribery Act 2010 and in accordance with section 12 of the Bribery Act 2010; and occurs when a person or an organisation, agrees, agrees to receive, authorises, offers, promises, provides, gives, pays, solicits or accepts anything of value (directly or indirectly):

  • To/from another person with the intention to induce that person to perform a function or activity improperly or to reward a person for the improper performance of a function or activity;
  • To/from another person knowing or believing that accepting or requesting anything of value would be an improper performance of a function or activity;
  • To/from another person knowing or believing that a person will conceal the request, promise, offer, or gift from his or her employer while he or she is required to disclose this information; or
  • To/from a public official to obtain or retain business or to secure an advantage in business. This also includes the inducement to do or refrain from doing an act in the conduct of business which is in breach of that person’s duties to his or her employer or principal or is dishonest or illegal;

Bribery Act means the UK Bribery Act of the United Kingdom of Great Britain and Northern Island of 2010 or equivalent;

Business advantage means anything that helps our Company achieve its business goals;

Conflict of interest means any situation that occurs when an individual or organisation is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another;

Company means LUMENISITY LIMITED (company number 09971631), a company registered in England and Wales, whose registered office is at c/o Penningtons Manches Cooper LLP, Apex Plaza, Forbury Road, Reading RG1 1AX, UNITED KINGDOM;

Corruption means an act which is done with intent to give some advantage inconsistent with law and wrongful or unlawful use of official position to procure some benefit or personal gain.

Effective date means the date of the latest revision of this Policy;

Facilitation payments means unofficial payments or small, infrequent payments made to a Government Official made to expedite, obtain or secure, a routine action or an administrative process or to “smooth the path” of a transaction;

Kickbacks means payments made in return for a business favour or advantage and is defined as any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind which is provided, directly or indirectly, to any prime contractor prime contractor employee, subcontractor, or subcontractor employee, for the purpose of improperly obtaining or rewarding favourable treatment in connection with a prime contract or in connection with a subcontract relating to a prime contract. The attempts and the offers to provide kickbacks are prohibited;

Policy or ABAC Policy meansthis written Policy;

Third Party means any natural person, individual or legal entity with whom our Company interacts and who poses, due to the nature of their business, a bribery risk. Third parties are held to the same high standards of honesty, integrity and fairness including through contractual provisions requiring compliance with this policy and all relevant applicable directives, laws, statutes, regulations, and codes relating to anti-bribery and anti-corruption including but not limited to the Bribery Act 2010 and all applicable international anti-corruption laws.



  • Read, understand, and comply with this Policy;
  • Comply with Company’s Policies;
  • Report immediately any concerns related to this Policy;
  • Complete assigned training related to this Policy when required.


Our company does not tolerate behaviour that may contravene the Bribery Act 2010 or related legislation and all forms of Bribery are criminal offences that are strictly prohibited.

All Employees, Business Partners and Third Parties as defined in Section 2 of this Policy, must comply with the Bribery Act 2010 and all applicable laws, statutes, regulations, and codes from time to time in force in relation to this Policy and each Scope:

(a) Comply with all applicable laws, statutes, regulations, and codes relating to anti-bribery and anti-corruption including but not limited to the Bribery Act 2010 (Relevant Requirements);

(b)  Not engage in any activity, practice or conduct which would constitute an offence under sections 1, 2 or 6 of the Bribery Act 2010 if such activity, practice or conduct had been carried out in the UK;

(c)  Have and shall maintain in place its own policies and procedures, including but not limited to adequate procedures under the Bribery Act 2010, to ensure compliance with the Relevant Requirements and clause 4 and all its subsections, and will enforce them where appropriate; and

(d) promptly report to our Company any request or demand for any undue financial or other advantage of any kind received in connection with our Company.

(e) Business Partners shall ensure that any person associated with them who is performing obligations in connection with this Policy does so only on the basis of a written contract, which imposes on and secures from such person terms equivalent to those imposed on Business Partners in this Clause 4.2 (Relevant Terms). Business Partners shall be responsible for the observance and performance by such persons of the Relevant Terms and shall be directly liable to the Company for any breach by such persons of any of the Relevant Terms.

(f) For the purpose of this clause 4.2 the meaning of adequate procedures and whether a person is associated with another person shall be determined in accordance with section 7(2) of the Bribery Act 2010 (and any guidance issued under section 9 of that Act), sections 6(5) and 6(6) of that Act and section 8 of that Act respectively. For the purposes of this clause 4.2 a person associated with a Business Partner includes but is not limited to any subcontractor of a Business Partner.

(g) The prevention, detection and reporting of bribery and other forms of corruption or improper payments is the responsibility of all Business Partners.

(h) All written agreements with Business Partners must include, as a minimum, standard contract provisions relating to compliance with Anti-Bribery and Anti-Corruption Laws and this Policy.


Our Company requires all Business Partners and Employees covered by this Policy, to strictly comply with this Policy and the obligation to conduct business with the highest standards of honesty, integrity, and fairness in accordance with all applicable codes, laws, statutes, requirements, regulations, relating to bribery, corruption, fraud and improper payments including but not limited to the Bribery Act 2010 (the “Bribery Act”), the Foreign Corrupt Practises Act 1977 (the “FCPA”) and the Proceeds of Crime Act 2002 (the “POCA”) with extraterritorial reach when applicable and provided that in jurisdictions where local laws or regulations set stricter rules than those set out in this Policy, the stricter rules must always prevail. Depending on location, and other factors, other Anti-Bribery and Corruption Laws may apply under the circumstances.


It is prohibited to make and accept facilitation payments or any kickbacks of any kind.

Our Company avoids any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by the Company.

Employees and Business Partners must never make, offer, solicit or encourage facilitation payments under any circumstances.


Gifts, entertainment, hospitality, and other courtesies including, but not limited to, cash, gratuity, hospitality, such as meals, hotels, and invitations to events, can, in certain circumstances, all be considered as bribes or corrupt payment. In order to avoid potential conflicts of interest, our Company discourages the giving or receiving gifts or hospitality by Business Partners. Gifts and entertainment may never be offered, given or received for purposes of performing or causing someone to perform (or refrain from performing) a function improperly or other than impartially. You should make appropriate inquiries to ensure that any gifts or entertainment or hospitality comply with Company Policies and any other applicable law and any gifts and entertainment relating to Government Officials require the prior approval of the Company. You should follow these rules:

  • Must be without corrupt intent;
  • Must never be in cash;
  • Must be made in good faith;
  • Must be reasonable in cost, quantity and frequency;
  • Must be ordinary and customary in the context of industry standards;
  • Must not create a conflict of interest or compromise the integrity or reputation of anyone;
  • Must not involve activities or behaviours that may be morally questionable or cause embarrassment to the parties involved;
  • Must comply with all applicable laws, regulations, and Company policies.


Charitable or political contributions represent a high corruption risk. Any charitable donation or contributions or sponsorship granted to any individual, organisation, entity with the intention, either real or suspected, to influence a decision to corruptly gain an advantage or benefit is strictly prohibited. Because of the risk of an actual or apparent conflict of interest, you may not make political contributions of any kind on behalf of the Company. As a minimum, all such donations must be made directly by the Company and only to officially and recognised organisations, never to political parties, individuals public officials, or any other individual, besides, donations must never be paid in cash. All payments must be properly documented in Company financial records. Before offering or making any charitable donation on behalf of the Company (i) outside of the Company’s formal, charitable matching programs, or (ii) to a Government Official or an organization associated with a Government Official, you must obtain prior approval of the Company.


Under limited circumstances and as long as it complies with the Company’s Policies, reasonable and bona fide expenditures, such as travel and lodging expenses directly related to legitimate business and offered in good faith, can be paid or reimbursed. Before seeking to offer, provide or receive sponsored travel, lodging and/or reimbursement similar expenses, you must at a minimum obtain prior approval from our Company. Payment of travel or lodging expense may never be received or given for the purpose of inducing or rewarding someone to perform their business functions improperly or to improperly influence an official decision. Any payment or reimbursement of these expenses must comply with Company’s Gifts and Hospitality Policy and be properly documented and recorded. Any question as to the propriety of offering, providing or receiving travel, lodging or similar items should be directed to our Company.


Our Company does not tolerate conduct transactions that involve benefit, property or proceeds resulting from crime including bribery, fraud and tax avoidance. Conducting those transactions may result in breach of anti-money laundering laws including but not limited to the Proceeds of Crime Act 2002 (“POCA”) and may require external reporting.


Tax evasion and the facilitation of tax evasion in all forms is a criminal offence. Our Company will not tolerate behaviour that facilitates in evading tax obligations or conceal or turn a blind eye to tax evasion.


Any request by a Third Party to transfer a payment to a bank not domiciled in the country of establishment of said Third Party and/or the Company is strictly prohibited.


Unless authorised in advance by the Company, any request by a Third Party to make a payment to another Third Party in the name and on the behalf of the first Third Party whether or not the second party is domiciled in the same country as the Company or the first Third Party is strictly prohibited.




Any current or potential conflict of interest including business, familial, financial, personal, management interest and other interest, outside the Company that might influence any Employee, Business Partner or Third Parties while conducting business for or on behalf of the Company shall be considered as conflicting and must be disclosed as soon as it becomes known or should reasonably have become known.

Line managers for Employees and Business contact in the Company for Business Partner and Third Parties, must be informed of any conflict of interest in writing as soon as it arises.


Company employees, to whom this policy applies, who violate this Policy shall be subject to disciplinary action, which could result in dismissal for gross misconduct and shall be subject to any other legal action required by the Company.

Business Partners and Third Parties in relation with our Company which violate this Policy shall be subject to business and legal consequences and may have their contract terminated with immediate effect as well as prohibition to engage in business relation with our Company.

The Policy violation could also subject the individual who committed the violation to severe civil and criminal penalties, including substantial fines and potentially lengthy imprisonment.


All books and records must be kept accurately and in reasonable detail and must fairly reflect all transactions and disposition of assets, with adequate supporting documentation complying with all applicable rules, laws and regulations.

All accounts, invoices, and other records relating to dealings with Third Parties, including suppliers and customers, should be prepared and maintained with strict accuracy and completeness.

Keep financial records and have appropriate internal controls in place evidencing the business reason for giving and/or receiving payments from/to Third Parties. No accounts must be kept “off-book” to facilitate or conceal improper or unauthorised Payments.


Training on Anti-bribery and Corruption Laws is provided for all of our employees during the induction process and this Policy will be communicated, where appropriate, to Business Partners in relation with the Company.



Employees and Business Partners are encouraged to raise any concerns about any issue or suspicion of malpractice at the earliest possible stage. Any concerns, doubt or issues about a possible violation of this Policy in connection with the Company should be immediately reported to the Company and/or to any of the following people:

  • Your Line manager or a higher-level manager
  • Legal Department
  • By website by completing the form “Contact us”
  • By Email to:


Retaliation in any form against an employee who has, in good faith, disclosed a violation or a possible violation of this Policy is strictly prohibited.