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Effective: 05.15.2025

1. Purpose and Scope

This Anti-Corruption and Bribery Policy outlines Vast Audio LLC’s commitment to conducting business ethically and in compliance with all applicable anti-bribery and anti-corruption laws. We maintain a zero-tolerance stance on bribery and corruption in all jurisdictions where we operate.

This policy applies to all employees, officers, directors, contractors, consultants, temporary staff, interns, agents, representatives, and any third parties working on behalf of Vast Audio LLC (collectively, “workers”).

2. Policy Statement

We are committed to:

  • Acting with integrity, fairness, and professionalism in all business dealings.
  • Enforcing robust procedures to prevent, detect, and respond to bribery and corruption.
  • Complying with all applicable anti-corruption and anti-bribery laws in the United States and all countries where we operate or do business.

3. What Is Bribery?

Bribery is the act of offering, promising, giving, accepting, or soliciting an advantage (monetary or otherwise) as an inducement for an action that is dishonest, illegal, or a breach of trust. Bribes can include:

  • Cash payments
  • Gifts, travel, or entertainment
  • Loans or discounts
  • Services or favors
  • Political or charitable donations

Examples:

  • Offering a Bribe: Providing concert tickets to a client to secure a contract.
  • Receiving a Bribe: Accepting employment for a relative from a supplier in return for favorable treatment.
  • Bribing a Foreign Official: Paying extra to a customs officer to expedite shipment clearance.

4. Gifts and Hospitality

Gifts and hospitality may be given or received only if all the following conditions are met:

  • Not intended to gain or reward a business advantage.
  • Complies with applicable laws.
  • Does not involve cash or cash equivalents (e.g., gift cards).
  • Is of reasonable value (typically under $25 USD).
  • Is appropriate in context (e.g., end-of-year token gift).
  • Is provided transparently, not secretly.
  • Prior approval is obtained for any gifts to or from government officials or politicians.


Note: When in doubt, seek managerial or HR approval prior to offering or accepting gifts.

5. Unacceptable Behavior

It is strictly prohibited to:

  • Offer or accept any bribe intended to influence a business outcome.
  • Offer or accept hospitality or gifts in exchange for favorable treatment.
  • Make “facilitation payments” or “kickbacks”.
  • Use personal relationships to gain business advantages.
  • Retaliate against anyone for refusing to engage in bribery or for reporting concerns.
  • Engage in any action that creates the appearance of impropriety.

6. Facilitation Payments and Kickbacks

Vast Audio LLC does not permit facilitation payments or kickbacks under any circumstances.
If you are ever asked to make such a payment:

  • Question the purpose and request a receipt.
  • Refuse the payment if improper.
  • Report the incident immediately.

7. Political and Charitable Donations

No political or charitable donations may be made on behalf of the Company without prior written approval from executive leadership.

8. Recognizing and Responding to Red Flags

Be alert for warning signs, including:

  • Requests for unusually high commissions.
  • Payments requested in cash or offshore accounts.
  • Lack of formal contracts or documentation.
  • Pressure for lavish entertainment or unrecorded gifts.
  • Requests for employment of friends or family of business partners.
  • Invoices that do not match goods or services rendered.

If you identify a red flag, report it immediately.

9. Your Responsibilities

You are expected to:

  • Read, understand, and comply with this policy.
  • Avoid actions that could lead to a breach.
  • Report any concerns or suspicions promptly.

Violations of this policy may result in disciplinary action up to and including termination of employment or contract.

10. Record-Keeping

We must maintain transparent and accurate records. You must:

  • Record all gifts or hospitality given or received.
  • Submit expenses in line with company policy, clearly explaining their purpose.
  • Never maintain off-the-books accounts.

11. Reporting Concerns

You are encouraged to report any concern regarding bribery or corruption through any of the following channels:

  • Your direct manager
  • Human Resources

Reports made in good faith are protected from retaliation. False reports made maliciously may be subject to disciplinary action.

12. Protection Against Retaliation

We prohibit retaliation against individuals who report concerns in good faith. If you believe you have been retaliated against, notify HR immediately. Employees may also pursue resolution through the Company’s Grievance Procedure.