Anti-Bribery and Corruption Policy

Policy Brief and Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially and ethically responsible manner.

Our reputation and success as a company is built upon a foundation of integrity – a commitment to act within the highest ethical standards and to conduct our business honestly and legally hence, any taint of bribery and corruption can significantly tarnish our Company’s reputation and image. Our Code of Conduct and this policy reflect this commitment.


It is our policy to conduct all of our business in an honest and ethical manner.

We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by the laws in all the areas where we are registered and do business in with respect to our conduct both at home and abroad.


This policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, research and site personnel, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of Nigeria). This policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

In the context of this policy, third-party refers to any individual or organization our Company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

Any arrangements our Company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

This policy covers:

  • Bribes
  • Gifts and hospitality
  • Facilitation payments
  • Political contributions
  • Charitable contributions

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. Bribes are not limited to cash, but can take many forms ranging from lavish entertainment to in-kind services to offers of employment. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it (passive), they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). You must not bribe an official anywhere in the world. Health Care Professionals (HCPs) are considered officials and the provisions of this policy applies to our interactions with them. You must not accept bribes in any degree and if you are uncertain about whether something is a bribe or a gift or act of hospitality, you must seek further advice from the Company’s compliance officer.

Gifts and hospitality

The Company accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

  • It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favors or benefits
  • It is not made with the suggestion that a return favor is expected.
  • It is in compliance with local law
  • It is given in the name of the Company, not in an individual’s name
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
  • It is appropriate for the circumstances (e.g. giving small gifts around religious holidays, or as a small thank you to a company for helping with a large project upon completion and must be pre-approved by the Compliance Officer).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given/received openly, not secretly.
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
  • It is not above a certain excessive value, as pre-determined by the Company’s Compliance Officer (usually in excess of $100). In line with the other requirements under 3.2 on Gifts and Hospitality, gifts should be of nominal value and in no case greater than $50, otherwise will require pre-clearance with the Compliance Officer.
  • It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the Company’s Compliance Officer.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted but must be declared and disclosed to the Compliance Officer immediately and as soon as possible no later than 24 hours of receipt.

The Company recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. As good practice, gifts given and received should always be disclosed to the Compliance Officer. Gifts from suppliers should always be disclosed.

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Compliance Officer should be sought.

Facilitation Payments and Kickbacks

The Company does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognize that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

The Company does not allow kickbacks to be made or accepted. We recognize that kickbacks are typically made in exchange for a business favor or advantage.

The Company recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

  • Keep any amount to the minimum.
  • Ask for a receipt, detailing the amount and reason for the payment.
  • Create a record concerning the payment.
  • Report this incident to your line manager and Compliance Officer immediately and as soon as possible no later than 24 hours after the incident has occurred.
Political Contributions

We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

We understand that some employees or affiliates of 54gene may have political affiliations and wish to make personal contributions. Employees do so on their sole discretion and not on behalf of 54gene and must disclose any political contributions to the Compliance Officer to assess whether any conflicts of interest would arise and prevent same.

Charitable contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Compliance Officer.

Requests for charitable contributions/donations shall follow our third party onboarding and due diligence procedures. Contributions to charity organizations affiliated with any public official shall be reviewed thoroughly to ascertain that there are no red flags for our contributions; and can only be made upon express approval from the Compliance Officer. All due diligence activities relating to donations shall be documented.

All charitable contributions should be publicly disclosed.

Your Responsibilities

You must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption.

You are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

As an employee or affiliate of 54gene, it is your responsibility to prevent any form of bribery and corruption. If you notice a colleague or a superior engaging in any of the prohibited acts under this policy, you may report using the Company’s grievance policy or whistleblowing mechanism. Whistleblower reports can also be made anonymously and the company ensures that reporters are not retaliated against and punishes any such retaliatory action.

You must notify your manager OR the Compliance Officer or the confidential helpline as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred or may occur in the future.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Employees who fail to make a report may be considered complicit to the misconduct.

54gene reserves the right to terminate our contractual relationship with other workers and/or third parties if they breach this policy.


We keep financial records and have appropriate internal controls in place which evidence the business reason for making payments to third parties.

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. To avoid the facilitation or concealment of improper payments, no accounts may be kept “off-book”.

How To Raise a Concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your line manager OR the Compliance Officer or through the confidential helpline.

The Company will familiarize all employees with its whistleblowing procedures so employees can vocalize their concerns swiftly and confidentially

What to do if you are a victim of bribery or corruption

It is important that you tell the Compliance Officer or the confidential helpline as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.


Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment or retaliatory action as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Compliance Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Company’s Grievance Procedure.

Training and Communication

Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis.

Our zero-tolerance approach to bribery and corruption shall be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them via our contracts, newsletters and periodic townhall sessions to be carried out and as appropriate thereafter.

Who Is Responsible for The Policy

The board of directors and executive team have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Compliance Officer has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

Monitoring and Review

The Compliance Officer will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Employees are invited to comment on this policy and suggest ways in which it might be improved.

Comments, suggestions and queries should be addressed to the Compliance Officer.

Signed on the 29th of April 2020 for and on behalf of Stack Diagnostics Limited trading as 54Gene

Abasi Ene-Obong

Chief Executive Officer