Anti-Corruption Policy

SUSTAINABLE CAPITAL PLC has a zero tolerance approach towards bribery, corruption and fraud. The company is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever we operate.

The objectives of the Anti-Corruption Policy are:

1. Promotion of corruption awareness;
2. Improvement of transparency of decisions and actions;
3. A safe environment in which to expose corruption; and
4. Avoidance of all forms of corrupt practices.

This policy applies to all persons working for SUSTAINABLE CAPITAL PLC or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Specifically, you must not:

a. give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b. accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or
c. give or offer any payment (sometimes called a facilitation payment)to a government official in any country to facilitate or speed up a routine or necessary procedure;
d. threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining SUSTAINABLE CAPITAL PLC'S image or reputation, or promoting the company Goals.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an induce mentor reward for any preferential treatment (for example, during contractual negotiations or a tender process). Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in the name of Sustainable Capital PLC – not your own name. Promotional gifts of low value (up to 30 Euros) may be given to business partners and we can accept equivalent gifts from them.

You must declare and keep a written record of all hospitality or gifts given or received. If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager.

Anyone who refuse to accept or offer a bribe, or those who raise concerns or report known or potential wrong doings, may be worried about possible repercussions. SUSTAINABLE CAPITAL PLC encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be unfounded. Proper consideration will be given to confidentiality of the individuals reporting possible cases of bribery or corruption.

SUSTAINABLE CAPITAL PLC is strongly committed to ensuring no one suffers any detrimental treatment 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.

Corruption is misuse of office for personal gain. Corruption in its wider meaning is abuse of position-related trust. Corruption is a societal phenomenon expressed in many forms, therefore it is misleading to consider corruption as mere violation of legal norms. Corruption can be encountered in the public and private sector as well as the third sector. 

Forms of corruption are for example bribery, influence peddling, preferential treatment, influencing of decisions for own interests, embezzling property or other resources, blackmail, abuse or trade of inside information, unequal treatment for own interests, buying of votes, etc.

Conflict of interests is a situation where a person’s economic or other interests
may apparently or actually influence the proper performance of official duties. Conflict of interests must be acknowledged, recorded and borne in mind upon performance of official duties. Conflict of interests does not always mean corruption; however, it can lead to corruption (transaction with oneself or a related person).

Transparency means rules, actions and decisions that enable the public to easily get answers to questions of why, what and how much. Transparency increases the trustworthiness of institutions. This, in turn, reduces corruption.


Last updated
July 2023