Purpose
The purpose of this policy is to affirm HyperGen Inc.’s commitment to ethical business practices and full compliance with all applicable anti-collusion, anti-corruption, and anti-bribery laws and regulations. This policy is designed to prevent and detect collusion, bribery, corruption, and other forms of unethical or unlawful conduct in all company activities.
Scope
This policy applies to all employees, officers, directors, contractors, agents, and business partners of HyperGen Inc., including any third parties acting on the company’s behalf.
Policy Statement
HyperGen Inc. is committed to conducting business with integrity, transparency, and fairness. We strictly prohibit all forms of collusion, bribery, and corruption, whether direct or indirect. These behaviors undermine the trust of our clients, partners, and the public and are not tolerated under any circumstances.
Guidelines
1. Prohibition of Collusion
- Employees and representatives must not engage in agreements or discussions with competitors or other parties that limit competition or manipulate the procurement or bidding process.
- Prohibited activities include price-fixing, bid-rigging, market allocation, or any coordination that restricts free and fair competition.
2. Prohibition of Corruption and Bribery
- No one acting on behalf of HyperGen Inc. may offer, give, solicit, or accept any bribe or corrupt payment, including facilitation payments or kickbacks.
- Bribes may include anything of value intended to improperly influence a business decision or secure an unfair advantage, whether in the public or private sector.
3. Gifts and Hospitality
- Modest gifts or hospitality may be given or received only if they are reasonable, infrequent, and not intended to influence a business outcome.
- All such exchanges must comply with company guidelines and be fully transparent and documented.
4. Third-Party Conduct
- HyperGen Inc. expects all third-party vendors, consultants, and partners to comply with this policy.
- Appropriate due diligence will be conducted before engagement, and non-compliant parties will not be retained.
5. Reporting Concerns
- Any employee who suspects collusion, bribery, or other violations of this policy is encouraged to report it immediately.
- Reports may be made confidentially through HyperGen Inc.’s ethics hotline or directly to the compliance officer.
- Retaliation against whistleblowers is strictly prohibited.
6. Training and Awareness
- HyperGen Inc. will provide regular training on anti-collusion and anti-corruption principles to relevant employees, particularly those involved in procurement, sales, or client engagement.
7. Compliance Monitoring and Enforcement
- The company will monitor business practices for compliance with this policy and investigate any reported or suspected violations.
- Any breach may result in disciplinary action, up to and including termination of employment or contract, and may also lead to legal consequences.
8. Review and Amendments
- This policy will be reviewed annually and updated as needed to reflect changes in legal requirements, best practices, or operational needs.
Responsibilities
All employees and business partners are responsible for understanding and adhering to this policy. Managers are expected to reinforce these standards and lead by example in promoting ethical conduct.
Conclusion
HyperGen Inc. is dedicated to maintaining the trust of our clients, partners, and the public by upholding the highest standards of honesty and accountability. Through compliance with this Anti-Collusion and Anti-Corruption Policy, we safeguard the integrity of our business and the fairness of the marketplace.