PureCloud Inc & PureCloud d.o.o., (“PureCloud”, the “Company”, “We”) demands the highest standards
of integrity and ethical conduct in its business dealings. We will not tolerate any bribery or
corrupt practices related to our business activities from our employees or business partners. We
are committed to transparent reporting and to taking all other reasonable measures which avoid
PureCloud’s involvement in bribery or corruption.
Bribery and corruption undermine the rule of law and the principle of fair competition. Such
activities entrench bad governance, hindering efforts to alleviate poverty and often contributing
to economic instability and human rights abuses. Whilst the risk of bribery exists in all
geographies, sectors, and transactions, PureCloud understands that steps can be taken to mitigate
the inherent risk of corrupt behavior. This Anti-Bribery and Anti-Corruption Policy (the “Policy”)
aims to inform PureCloud management, employees, and business partners about our intention to
closely monitor corruption risk and to take immediate action if evidence of corrupt activity is
2. Objective of the Policy
The objective of this Policy is to provide a procedure by which PureCloud and its subsidiaries
conduct its business, ensuring honest and ethical business practices which reﬂect the highest
standards of integrity and are in compliance with all applicable laws and regulations.
3. Application of the Policy
This Policy applies to all PureCloud employees, contract staff, or business partners working on
behalf (“PureCloud Employees”). PureCloud Employees must never accept or give a bribe,
facilitation payment, kickback, or other improper payment under any circumstances.
This includes transactions with:
- Foreign or domestic government ofﬁcials.
- Any private company or person.
- In the conduct of domestic or international business.
- Where payment is received directly or where it is received through a third party
(agent, contractor, representative, distributor, or business partner).
4. Management Responsibilities
PureCloud’s management takes responsibility for encouraging a transparent and ethical culture at
PureCloud. Their role includes:
- Regularly undertaking periodic and high-level risk assessments of its business
- Responsibility for ensuring that the Policy is well communicated to PureCloud
Employees, contractors, suppliers, and business partners alike.
- Encouraging trust and dialogue with employees, so that they can voice their
concerns if they witness any dishonest activity.
- ‘Leading by example’, behaving with the utmost integrity at all times.
5. Prohibited Behavior
PureCloud prohibits the following behavior from PureCloud Employees:
- Bribery of national public ofﬁcials or private sector counterparts, including
- Bribery of foreign public ofﬁcials and ofﬁcials of public international
- Embezzlement of property in the private sector.
- Abuse of function.
- Illicit enrichment.
- Laundering or concealment of proceeds of crime.
- Obstruction of justice.
6. Prevention of Improper Payments
PureCloud strictly prohibits the use of improper payments. This includes:
- The improper or concealed use of ‘kickbacks’, subcontracts, purchase orders,
consultancy agreements, or payment of agents to secure business or proﬁt.
- The direct or indirect offer, payment, soliciting, or acceptance of bribes. For
the avoidance of doubt this includes:
- To directly or indirectly offer, give or agree to give or offer a loan, reward,
advantage or beneﬁt of any kind to a public ofﬁcial, political party, party ofﬁcial or political
candidate as consideration for an act or omission by the recipient in connection with the
performance of the recipients' duties or functions with the government. Examples include
applications for environmental permits, customs procedures or, judicial proceedings.
- To induce an ofﬁcial to use his or her position to inﬂuence any acts or
decisions of government for the purposes of obtaining an advantage in the course of business, or
to agree, or comply, with any demands for a bribe made by a public ofﬁcial.
7. Gifts and Hospitality
PureCloud recognizes that reasonable and proportionate gifts and hospitality are a legitimate
contribution to good business relationships between PureCloud and its business partners. However,
judgment must be used to ensure these are reasonable and ethical. For instance:
- The cost or expense of a gift, meal, or entertainment must be reasonable and in
good faith directly connected to a legitimate business promotional activity or the performance
of existing contracts.
- When considering what is a reasonable expense, PureCloud Employees should
consider the frequency with which such expenses are incurred for a particular ofﬁcial.
- PureCloud Employees are forbidden from soliciting gifts or hospitality, and
PureCloud Employees must endeavor to avoid conﬂicts of interest and the appearance of conﬂicts
- Some examples of impermissible gifts include:
- Any gift or entertainment that would be illegal (anything offered to a
government ofﬁcial in breach of local or international bribery laws.
- Gifts or entertainment involving parties engaged in a tender or competitive
- Any gift of cash or cash equivalent (such as gift certiﬁcates, loans, stock,
- Any gift or entertainment that is a ‘quid pro quo’ (offered for something in
- Any entertainment that is indecent, or sexually-oriented.
8. Supply Chain Risk Management
When selecting potential business partners, PureCloud endeavors to work with
those that are like-minded in their approach to maintaining high ethical standards as well as
demonstrated legal and regulatory compliance. PureCloud will include risk management measures in
its procurement practices, for example:
- PureCloud’s contractual terms will contain an ethical policy, including a
statement on bribery and corruption.
- Before entering into a new contractual relationship, PureCloud will undertake:
- A risk assessment.
- A due diligence review of the business partner.
Once the business relationship is successfully approved, a periodical review
the business relationships will be ongoing, although the level of oversight required will vary
depending on the risks identified upon initial assessment.
9. Training and Communication of the Policy
A copy of this Policy has or will be made available to all PureCloud Employees as well as its
auditors, legal counsel, and other advisors. It is also posted on the website at
PureCloud will provide periodic compliance training on this Policy and good practices. The aims of
the training are:
- To ensure that the Policy is consistently taken into account by PureCloud
Employees during all their business dealings.
- To provide practical assistance to PureCloud Employees on how they should
respond and exercise good judgment to situations where it may be unclear what qualiﬁes as
improper payments or corruption.
10. Reporting Violations
PureCloud Employees that become aware of actions that could constitute a violation of this Policy
are required to report it to their immediate supervisor. However, if the PureCloud Employee is not
comfortable reporting the matter to their immediate supervisor, or does not feel their immediate
supervisor has taken sufﬁcient action, they are encouraged to report the matter to the Head of
No PureCloud Employee will suffer undue consequences for:
- Reporting suspected or actual violations.
- If PureCloud loses business opportunities as a result of his or her refusal to
pay or accept bribes.
11. Consequences of Non-Compliance with Policy
Any PureCloud Employee who is found to be giving or taking bribes or partaking in any other
corrupt acts will be subject to disciplinary action which may ultimately lead to dismissal. The
violation of this Policy may also be a violation of certain laws and, if appropriate, PureCloud
may refer the matter to the appropriate regulatory authorities which could lead to criminal
12. Remedial Measures
Should evidence of corrupt practices be uncovered, PureCloud will consider a full range of
remedial measures including but not limited to:
- Voluntary restoration of damages or loss caused by the offense.
- Recovery of ill-gotten gains (e.g. proceeds of the corrupt act).
- Acceptance of an external compliance monitor.
- Corrective organizational actions (e.g. removal or other disciplinary measures
against responsible employees).
13. Review of Policy
This policy will be reviewed and evaluated regularly by the Board of Directors and the Management.
The review will consider:
- Whether the policy is effective in ensuring compliance by PureCloud Employees.
- Any updates and recommendations from recognized international anti-bribery and
corruption NGOs and bodies, for example:
- The United Nations Convention against Corruption (“UNCAC”).
- Council of Europe Conventions regarding corruption.
Should you have any concerns or queries regarding this policy or believe that you may have become
aware of any breach thereof, you are encouraged to contact the company compliance ofﬁcer or the
Chief Executive Ofﬁcer, James Anderson,