SecureSearch Screening Services Private Limited (“SecureSearch”) is committed to conducting business with integrity, transparency, and the highest standards of ethical conduct. We operate a strict zero-tolerance policy towards bribery and corruption in all forms, whether direct or indirect, and whether involving public officials or private parties.
This Statement summarises our public commitment and the standards we expect of everyone who works with or on behalf of SecureSearch. It is supported by our detailed internal Anti-Bribery Policy, which sets out the procedures, controls, and obligations that apply to our personnel.
This Statement applies to all individuals and entities acting on behalf of SecureSearch, including:
- Directors, officers, and employees;
- Temporary staff, interns, and consultants;
- Contractors, subcontractors, agents, and intermediaries;
- Suppliers, vendors, business partners, and any other third parties providing services to or representing SecureSearch.
SecureSearch conducts its business in compliance with all applicable anti-bribery, anti-corruption, and anti-money laundering laws in the jurisdictions in which it operates and the territories in which its clients operate. These include, but are not limited to:
- The Prevention of Corruption Act, 1988 (India), as amended;
- The UK Bribery Act 2010;
- The Proceeds of Crime Act 2002 (UK);
- The Fraud Act 2006 (UK);
- The US Foreign Corrupt Practices Act (FCPA) 1977, as amended;
- The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
Where the requirements of applicable laws differ, the more stringent standard prevails.
SecureSearch and those acting on its behalf shall not, directly or indirectly:
- Offer, promise, give, request, or accept any bribe, kickback, or improper benefit of any kind, whether to or from a public official or a private party;
- Make facilitation payments, regardless of whether such payments may be permitted under local law or custom;
- Use intermediaries, agents, or third parties to commit acts of bribery or corruption on our behalf;
- Offer or accept gifts, hospitality, or entertainment that are intended, or could reasonably be perceived, to influence a business decision.
All gifts, hospitality, and entertainment are governed by approval and recording requirements set out in our internal Anti-Bribery Policy.
SecureSearch expects all third parties acting on its behalf or providing services to the organisation to conduct business ethically and in compliance with all applicable anti-bribery and anti-corruption laws.
Before engaging any third party, SecureSearch takes reasonable steps to ensure that the third party:
- Has a legitimate business purpose for the services provided;
- Is compensated at reasonable market value;
- Agrees to comply with applicable anti-bribery and anti-corruption laws.
Where appropriate, SecureSearch may require third parties to acknowledge our anti-bribery standards in writing, sign contractual commitments confirming compliance, and cooperate with any investigation of suspected misconduct. SecureSearch reserves the right to terminate any relationship with a third party found to be involved in bribery or corruption.
SecureSearch encourages anyone with knowledge or reasonable suspicion of bribery, corruption, or other improper conduct involving SecureSearch to report it promptly. This includes employees, contractors, clients, vendors, suppliers, business partners, and members of the public.
Reports can be made through the following confidential channel:
Email: ethics@securesearch.co.in
Reports may be made anonymously and will be reviewed by SecureSearch’s Compliance Officer. All reports will be treated confidentially to the extent permitted by applicable law. SecureSearch will not tolerate retaliation of any kind against any person who reports a concern in good faith.
Compliance with this Statement and our internal Anti-Bribery Policy is overseen by SecureSearch’s Compliance Officer, with executive accountability resting with the Board of Directors. The supporting policy is reviewed annually and updated as required to reflect changes in applicable laws, business operations, and industry best practices.
Breaches of this Statement or the supporting policy will not be tolerated and may result in disciplinary action up to and including termination of employment, termination of contractual relationships, and referral to relevant authorities where appropriate.
