Effective Date: 17th November 2023

1. Introduction
Xaura.io (“we,” “us,” or “our”) is committed to conducting its business ethically and in compliance with all applicable anti-bribery laws. This Anti-Bribery Policy outlines our commitment to preventing bribery and corruption in all aspects of our business operations.

2. Policy Statement

• Xaura.io strictly prohibits any form of bribery, whether direct or indirect, and corruption in all of its business dealings.
• We are committed to acting professionally, fairly, and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to prevent bribery.
  
  

3. Who and What the Policy Applies To

• This policy applies to all employees, contractors, consultants, or any other individuals representing Xaura.io in any capacity.
• It applies to all aspects of our business operations, including interactions with clients, suppliers, government officials, and other third parties.
  
  

4. Prohibited Activities

• No employee or representative of Xaura.io is permitted to offer, give, receive, or solicit any form of bribe, kickback, or facilitation payment.
  
  

5. Facilitation Payments

• Xaura.io prohibits facilitation payments, which are typically small, unofficial payments made to secure or expedite routine government actions.
  
  

6. Gifts and Hospitality

• Employees must exercise caution and seek guidance when giving or receiving gifts, hospitality, or entertainment to ensure compliance with anti-bribery laws.
  
  

7. Due Diligence on Third Parties

• We conduct due diligence on all third parties, including clients, suppliers, and partners, to ensure they adhere to anti-bribery standards.
  
  

8. Reporting Violations

• Any employee or third party who believes they have witnessed or are aware of a violation of this policy is encouraged to report it promptly. Reports can be made to Lisa Harrison-Evans, Business Operations Manager.
  
  

9. Consequences of Violations

• Violations of this policy may result in disciplinary action, termination of employment or contractual relationship, and legal action, as appropriate.
  
  

10. Training and Awareness

• Xaura.io provides training to employees to raise awareness of anti-bribery laws and the importance of compliance.
  
  

11. Review and Update

• This Anti-Bribery Policy will be reviewed periodically to ensure its effectiveness, and updates will be made as necessary.
  
  

12. Contact Information

For inquiries related to our Anti-Bribery Policy, please contact Lisa Harrison-Evans, Business Operations Manager, Xaura.io, Enterprise House, Harmire Enterprise Park, Darlington, DL12 8XT, 01325 792680.