Anti-Bribery Policy

1. Introduction

Celix Pharma is committed to conducting its business with integrity, transparency, and in compliance with all applicable laws and regulations, including the UK Bribery Act 2010. This Anti-Bribery Policy outlines our commitment to preventing bribery and corruption in all forms, whether directly or through third parties, and applies to all employees, contractors, agents, consultants, and any other parties associated with Celix Pharma.

2. Policy Statement

It is the policy of Celix Pharma to prohibit any form of bribery or corruption, whether offering, giving, receiving, or soliciting, in any business dealings, both domestically and internationally. We do not tolerate any actions that could compromise our integrity or damage our reputation. Bribery in any form is strictly prohibited, including facilitation payments.

3. Definitions

· Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of an individual or entity, or to gain an improper advantage.

· Facilitation Payment: Small payments or gifts made to expedite routine governmental actions or services.

4. Responsibilities

Management: Senior management is responsible for establishing and maintaining a culture of integrity and compliance with anti-bribery laws. They must ensure that adequate resources and training are provided to prevent bribery and corruption.

Employees: All employees must familiarise themselves with this policy and adhere to its principles. They are responsible for reporting any suspected instances of bribery promptly.

Third Parties: Celix Pharma expects all third parties, including agents, contractors, consultants, and suppliers, to comply with our anti-bribery standards. Contracts with third parties must include anti-bribery provisions.

5. Gifts, Hospitality, and Entertainment

Celix Pharma recognises that the exchange of gifts, hospitality, and entertainment is a common business practice. However, such exchanges must be reasonable, proportionate, and transparent. Employees must obtain prior approval for any gifts or hospitality exceeding a nominal value.

6. Reporting Procedures

Employees must report any suspected or actual instances of bribery or corruption to senior management, reports can be made anonymusly where possible and no employee will face retaliation for raising concerns in good faith.

7. Consequences of Non-Compliance

Violation of this policy may result in disciplinary action, up to and including termination of employment or contract. Additionally, individuals found guilty of bribery may face legal consequences, including fines and imprisonment.

8. Review and Updates

This policy will be reviewed regularly to ensure its effectiveness and relevance. Updates will be communicated to all employees and relevant parties.

By adhering to this policy, we demonstrate our commitment to conducting business ethically and responsibly, and to upholding the highest standards of integrity.

Approval 

Approved on behalf of the Management by Shantreddy Soogareddy, Co-founder & COO

on 14th March 2024