NFR Innovation Inc. Anti-Bribery Policy and Procedures

Version 1, 15 January 2021

1. Purpose

The purpose of this Policy is to assist staff and agents (including consultants, advisers, intermediaries or any other individual or business that acts on behalf of NFR Innovation Inc.) in identifying anti-bribery and corruption related issues and in understanding and complying with our related procedures.

2. What is bribery?

Bribery means giving or offering (as well as demanding or receiving) any undue advantage to or from:

3. Zero tolerance policy statement

NFR Innovation Inc. prohibits bribery and corruption in all business practices and transactions carried out by its staff and by agents acting on its behalf.

All staff and agents of NFR Innovation Inc. are protected from any penalty or adverse consequences for identifying concerns related to suspected bribery, for refusing to participate in bribery or refusing to pay a facilitation payment.

Staff and agents of NFR Innovation Inc. must not engage in bribery in connection with any dealings or activities involving private or public companies, government or public officials, organizations or individuals.

4. Facilitation payments

Facilitation payments are sums of money paid to receive preferential treatment for something the receiver is otherwise still required to do.

Facilitation payments of any kind are strictly prohibited under this policy. Staff or agents that are asked to make a facilitation payment should immediately report this to NFR Innovation Inc.

5. Gifts and hospitality

Staff and agents acting on behalf of NFR Innovation Inc. must never use gifts or hospitality to improperly influence the business decision-making process or cause others to perceive an improper influence.

As such, no gifts (including cash) or hospitality should be accepted or offered by staff or agents acting on behalf of NFR Innovation Inc., except where such gifts and/or hospitality are of little monetary value (e.g. meals, taxi fares, box of chocolates etc). Gifts and hospitality should only be offered for the purposes of better presenting NFR Innovation Inc. products or to establish cordial relations with prospective business partners. Staff and agents should disclose if they have been offered gifts and/or hospitality. All gifts and hospitality given and received will be recorded in the company gifts register.

6. Charitable and political donations

Charitable donations will never me made for the purpose of influencing a business decision-making process. All such donations (if made) will be made directly to selected charitable organisations and never to an individual. NFR Innovation Inc. does not make political donations of any kind.

7. Use of cash

No payment to or from any business counterparty shall be made in cash. Any exception to this rule requires advance written approval from NFR Innovation Inc.

8. Reporting

Any staff or agents that identify (or suspect) instances of bribery should report this immediately to:

Name: Mr. Dylan Dix, Managing Director, NFR Innovation Inc.

9. Investigation and sanctions

All actual or suspected cases of bribery will be fully investigated. Staff and agents that are found to be in breach of this policy could face disciplinary procedures.


The above is endorsed by Dylan Dix, Managing Director and Owner, NFR Innovation Inc.