Avature’s Anti-Bribery Statement


Avature upholds a high ethical standard and has zero-tolerance for bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, implementing and enforcing effective systems to counter bribery and corruption.
This statement is intended to outline Avature’s stand against bribery and corruption and to provide the tools and support necessary to identify, mitigate and raise any risks or concerns.

Our Standard

Our practices are in alignment with the UK Bribery Act 2010, the United States Foreign Corrupt Practices Act (FCPA) as well as any Anti Bribery legislation in the jurisdictions in which we operate.

While we consider Avature’s business and value chain are broadly at a low risk of bribery and corruption, we are not complacent. Avature requires all of its employees to abide by its Code of Conduct, which includes this Statement.

To broaden our efforts, we maintain the same high standards against bribery in all locations where we operate and we require all vendors and suppliers to adhere to Avature’s Code of Conduct for Suppliers. This statement requires vendors and suppliers to comply with applicable laws, maintain a high ethical standard and specifically includes the obligation of preventing and not benefiting or engaging with any form of bribery or unethical standard.

Bribery and Facilitation Payments

We do not tolerate any form of bribery and corruption. All of Avature employees must not directly or indirectly:

  • give, offer or promise a bribe;
  • receive, solicit or agree to accept a bribe,
  • or authorize anyone else to do so.

Bribery is giving or offering anything of value or any advantage, whether directly or indirectly, to any person, in order to induce that person or any other person to perform a function or activity improperly. Bribery is also requesting or receiving anything of value or any advantage, whether directly or indirectly, from any person, intending that, as a consequence, a relevant function or activity should be performed improperly, whether by you or another person. A bribe can be financial or otherwise, and can include giving or receiving money, loans, contributions or donations, travel, offers of employment, refunds, rebates, goods, services or anything else that could be considered to have value.

Gifts or entertainment may be construed as forms of bribery in certain circumstances. A bribe can also take the form of a “reward” and be paid after the improper performance of the relevant duty or obligation has taken place. Many countries have passed legislation criminalizing bribery. The sanctions for violating these laws can be severe, including significant individual and corporate fines, and even imprisonment. We do not condone, under any conditions, the offering or receiving of bribes or any other form of improper payments (including facilitation or “grease” payments). Even the appearance of a breach of anti-bribery or anti-corruption laws could do significant damage to Avature’s reputation. You should exercise particular care in dealings with Government Officials to ensure there can be no suggestion of impropriety.

Avature may be held liable for bribes paid by a third-party agent or consultant acting on our behalf. Take particular care when evaluating a prospective third party who might interact with a Government Official, customer, supplier or consumer on behalf of Avature. You must not engage a third-party agent or consultant if you have reasonable grounds to believe that the agent or consultant may attempt to bribe any person on behalf or for the benefit of Avature.

Transactions with Government Officials are not the same as conducting business with private parties, and are subject to special legal rules. If in doubt, seek guidance from the Legal Department to be certain that you are aware of, understand and abide by these rules.

Although you must never offer bribes to anyone or accept bribes from anyone, you need to be particularly careful not to engage in any bribery or improper dealings with Government Officials.


Who are Government Officials?

  • Employees or representatives of any government, government-owned, or
    government-controlled entity anywhere in the world, even low-ranking employees;
  • Any individual exercising a legislative, administrative or judicial function, whether
    appointed or elected;
  • Any candidate for or holder of public office;
  • Any official of a political party;
  • Any official, employee, or representative of a public international organization, such
    as the United Nations or World Bank;
  • Any member of a royal family;
  • Any child, spouse, parent, sibling, or other familial relation of the above.


You must not offer, promise, give or authorize any financial or other advantages to anyone (including a family member, relative or person associated with a Government Official) if the circumstances may give the appearance of seeking to influence the Government Official to obtain or retain business or an advantage in the conduct of business.

You must obtain prior written approval from Avature’s Legal Department before providing anything of value or any advantage to a Government Official.

Gifts and Entertainment

While gifts and entertainment among business associates can be appropriate ways to strengthen ties and build goodwill, they also have the potential to create the perception that business decisions are influenced by them. Avature is committed to winning business only on the merits of its services and people and complies with all legal requirements for giving and receiving gifts and entertainment.

You must:

  • Use sound judgment and comply with the law and any applicable customer policies regarding gifts and other benefits.
  • Never allow gifts, entertainment or other personal benefits to influence decisions or undermine the integrity of business relationships.
  • Never accept gifts or entertainment that are illegal, immoral or would reflect negatively on Avature.
  • Never accept cash, cash equivalents, stocks or other securities.

You may accept occasional unsolicited personal gifts of nominal value, such as promotional items, and may provide the same to customers and business partners, provided this complies with their applicable policies.

When in doubt, you should check with the Legal Department.

Tone from the Top

Avature’s management is committed to ethical business practices and understand the importance of top-level commitment to fostering a culture of integrity. Avature’s CEO, Dimitri Boylan, has personally communicated the Code of Conduct (of which this Statement is a part of) to all employees expressing its importance and requesting a personal commitment from all to ensure that Avature continues to embrace the principles set out in the Code, namely transparency, honesty and authenticity. The clear message from management is that creating a strong ethical culture, will not only promote our success, but will also give us a sense of immense pride in what we do.


To ensure a high level of understanding of the risks of Bribery and inappropriate gift behavior in our supply chains and our business, we provide yearly training to our staff globally.

Speaking Up

All employees are required to read and follow this Statement in conjunction with our Code of Conduct. We encourage asking questions and raising issues without fear of retaliation. Avature is committed to treating reports seriously and investigating them thoroughly.
If you wish to report a concern, you should either discuss the matter directly with your manager (as applicable) or report it by email to ethics@avature.net.
Failure to comply with these standards will be taken very seriously and will be subject to corrective measures that may result in disciplinary actions. This may include termination, claims for damages and the enforcement of criminal proceedings.

Monitoring and Review

We continue to monitor and work to improve the systems in place to ensure that our business remains free from bribery and corruption.
We perform annual reviews of the controls, designs and operative effectiveness of our financial procedures, including those tied to financial transactions. These reviews are carried out with independent auditors.