Last updated: October 24, 2023
Purpose, scope, and responsibility
This Anti-Bribery and Corruption Policy establishes principles that govern the actions of the DGP Capital team. It also explicitly states our intention and corporate obligation to act honestly and ethically in all of our business dealings.
This policy applies to all DGP Capital employees. The CEO of DGP Capital is the final authority for this policy. He oversees the assessment of bribery and corruption risks across the entire company, as well as, evaluating controls and policy effectiveness regarding any and all anti-bribery and corruption (AB&C) risks.
Policy statement
Bribery and corruption are explicitly forbidden by our company. They are illegal and can expose both any complicit employee and the entire company to fines and penalties, including imprisonment and reputational damage.
Bribery and corruption are in direct conflict with our company mission and values. They are also incompatible with the implicit and explicit promises we have made to our customers.
Just to be clear, at DGP Capital, bribery is absolutely never permitted. We will not seek to directly or indirectly influence others by offering, paying, or receiving bribes or any other means considered unethical, illegal, or harmful to our reputation.
All employees and representatives of DGP Capital are expected to decline any opportunity that would place our ethical principles and/or reputation at risk.
What is bribery and corruption?
According to the Cambridge Dictionary, “bribery is an attempt to make someone do something for you by giving the person money, presents, or something else that he or she wants.”
Items that can be used in bribery transactions include but are not limited to:
- Cash, cash equivalents (including credit or other gift certificates), stock, personal property, and assumption or forgiveness of a debt.
- Gifts, meals, travel, and entertainment.
- Political contributions made at someone’s request as an exchange.
- Charitable contributions made at someone’s request as an exchange.
The Cambridge Dictionary defines corruption as, “illegal, bad, or dishonest behavior, especially by people in positions of power.”
With regards to bribery, corruption has occurred even if:
- What was offered as a bribe does not produce the desired outcome.
- A person agrees to or provides direction for a bribe, but no bribe is ultimately paid out or offered.
Third parties
Using a third party does not reduce the liability a company has with regard to giving or receiving a bribe. Some common third parties involved in such transactions include consultants, agents, advisors, representatives, contractors, and subcontractors.
For our part, we commit to clarifying with third parties representing DGP Capital that we expect them to comply with our Anti-bribery and Corruption Policy. In some jurisdictions, if a business does not prevent bribery committed on its behalf by a third party, even though no one in the firm had actual knowledge of it, it can be convicted of a crime.
Reporting violations
All DGP Capital team members should seek clarification on any questions or concerns regarding any potentially dubious activities or any lack of clarity regarding this policy or its application.
If you are offered a bribe by someone who is conducting business with or wants to do business with DGP Capital, report it right away to our CEO.
If you are offered something of value and are uncertain whether you’re allowed to accept it, consider simply not accepting it. Alternatively, you can ask at one of our team meetings or email our CEO directly.
Violations can be reported anonymously by using the online customer inquiry form (available on the internet). Our whistleblower policy protects those who act in good faith and disclose concerns.