
ABAC Policy
MyBlood practices a zero-tolerance approach to bribery and corruption and is committed to acting lawfully, professionally, fairly, and with integrity in all its dealings and relationships and in implementing and enforcing effective systems to counter bribery and corruption in any form. We comply with all applicable anti-bribery and anti-corruption laws, including but not limited to Indian Prevention of Corruption Act, 1988 including its amendments (“PCA”), U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act (“UKBA”) and all applicable anti-bribery and anti-corruption laws where MyBlood operates, and to accurately reflect all transactions in MyBlood books and records. Even in countries where the local law does not prohibit such conduct, it is strictly prohibited for any resource/staff of MyBlood to make any payment to any person or persons, including public or private officials, customers, merchants or employees or consultants, or any other Third-party dealing with us to obtain or retain business, influence business decisions or secure an unfair advantage
The purpose of this Policy is to:
set out our responsibilities, and of those working with/for us, in observing and upholding our position on bribery and corruption;
provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues; and
lay out guardrails to identify potential non-compliances and provide guidance to comply with applicable anti-bribery and anti-corruption laws.
This Policy shall apply to all Employees, Volunteers, and Third-Parties who are working with or on behalf of MyBlood
The Policy shall become effective from _____.
Employee includes all directors, officers, employees, and interns engaged directly or indirectly, wherever located regardless of grade and position, in terms of all dealings and transactions in all regions where MyBlood operates. Third-party means any individual or organization who has business dealings with MyBlood and includes actual and potential business associates, donors, Non-Governmental Organisations (NGO), contractors, subcontractors, business partners, service providers, suppliers, distributors, business contacts, agents, and government bodies and officials or any other person associated with or acting on behalf of MyBlood.
The Governing Body of Hunger Heroes members has the overall responsibility for ensuring that this Policy complies with our legal and ethical obligations and that all those under our control and/or Third parties comply with it. Management at all levels is responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate and regular training on it.
BRIBERY AND CORRUPTION Bribery: Bribery is offering, promising, giving, or accepting any financial or other advantages, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. You must not engage in any form of bribery, in dealings with any foreign/ public official, private party, or any Third-party (such as an agent or intermediary) either directly or indirectly, in order to improperly influence any act or decision of a person, or to otherwise gain an improper benefit for the MyBlood. A bribe can take many forms, for example: money (or cash equivalents such as shares)
unreasonable gifts, entertainment, or hospitality; kickbacks; unwarranted rebates or excessive commissions (e.g., to sales agents or marketing agents); unwarranted allowances or expenses; political/ charitable contributions; uncompensated use of organizations services or facilities; and anything else of value.
Corruption Corruption is the abuse of entrusted power or position for private gain. Great care must be taken in dealing with government officials. No gift or payment may be given to government officials, directly or indirectly, for the purpose of, or that appears to be for the purpose of, seeking favorable arrangements or action by such officials. Please check with the legal team before giving any gift or payment to any government official. Kickbacks Kickbacks are typically payments made in return for a business favor or advantage. You must not make or accept kickbacks. Kickbacks are typically payments made in return for a business favor or advantage. A kickback is a form of corruption that involves two parties agreeing that a portion of their sales or profits will be kicked back (given back) to the purchasing party, in exchange for making the deal. Facilitation payment Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). You must not make facilitation payments. Certain countries may have a practice of ‘Facilitation payments’ but we do not partake in any of these, nor do we allow Third parties acting on our behalf, such as merchants, vendors, agents, customers, consultants, alliance partners, service providers, suppliers, and contractors to make any such payments. Anything of value Anything of value includes any benefits, favours, or advantages (with no minimum amount or threshold). It may be in any form, tangible (such as cash or cash equivalents, hospitality, cars, jewelry, home improvements, travel, loans, shares, etc.) or intangible (such as inside information, stock tips, and improper assistance in arranging a business transaction).
MyBlood is responsible for the acts done by Third-parties acting on our behalf. Therefore, no Third-party, acting on behalf of MyBlood may engage in any act that could be construed as an act of bribery or corruption, whether using MyBlood funds or their own personal funds or whether acting directly or through a middleman. MyBlood expects all those acting on our behalf to abide by our standards of ethics and integrity and, where necessary and appropriate, to follow our procedures. While engaging with Third-parties, Staff should ensure that they comply with MyBlood’ ABAC Policy.
This clause is to be read in conjunction with the Third-party risk management framework.
Intermediary
An Intermediary is a Third-party service provider, merchant, agent, consultant, distributor, contractor, vendor, supplier, or another Third party, whether an individual or an entity engaged on a contract basis or retained, in any business function that requires or involves interaction with any foreign/ public officials.
Due care must be taken in onboarding/ dealing with Intermediaries:
On-board Intermediary only on merit;
Conduct due diligence; and
Execute contracts with Intermediaries, considering Intermediary is aware of MyBlood’ ABAC policy
Employees are mandated to complete all required training(s), instructor-led, or web-based, related to the Code of Conduct, and the Policy on time. The Governance Risk & Compliance team will be responsible for the dissemination of the Policy and arrange training for Employees at the time of joining MyBlood and each year thereafter. MyBlood’s zero-tolerance approach to bribery and corruption shall be communicated to all Third parties at the outset of the MyBlood’s association with them and as appropriate thereafter. Wherever possible, all such Third parties shall also be sent a copy of this Policy at the outset of the said business relationship and periodically throughout the term of the relationship.
