Anti-Bribery Policy and Procedure

Anti-Bribery Policy


Policy Number: POL/2020/11



1. Purpose

The purpose of this Policy is to ensure that employees and stakeholders of the Company conduct business in an ethical manner and understand and adhere to the requirements of all applicable anti-bribery and ant-corruption laws and best practices.


2. Scope

This policy applies to all employees of STO Group of Companies and other stakeholders that deal with the Companies with respect to their activities, for or on behalf of the Company unless specified otherwise in their contract, appointment letter or any other guideline. The Policy covers major Anti-Corruption and Anti-Bribery Laws of Maldives and any other major international Anti-Bribery Laws that may be subject to any business dealings of the Company.


3. Policy Statement

The Company is committed to operate in an ethical manner and in compliance with applicable antibribery and anti-corruption laws and regulations in the Republic of Maldives and other jurisdictions in which it operates. The Company takes zero-tolerance approach to bribery and corruption and is committed to conduct all its business in an honest, transparent, and ethical manner. The Company aims to avoid acts which might reflect adversely upon its integrity and reputation.

Employees and stakeholders found to violate this policy may be subject to disciplinary action and penalty by the Company and may subject themselves and their Company to civil and criminal fines and prosecution and significant reputational damage.


4. Principles

·       Form of Bribery and Corruption

o   Bribes

o   Kickbacks

o   Extortion

o   Prohibited Payments


·       Application of the Policy

o   The Company, employees and stakeholders shall refrain from offering or accepting any form of bribe or benefits from the following, to again any unfair advantage.

o   Government Officials.

o   Non-Governmental Organizations.

o   Commercial Entities.


·       Anti-Bribery and Corruption Standards
It is prohibited for the Company or its employees and stakeholders to:

o   Give, promise to give, or offer, a payment, gift or hospitality to a third party or otherwise engage in or permit for a bribery offense to occur, with the expectation or hope that an advantage in business will be received, or to reward a business advantage already given.

o   Give, promise to give, or offer, a payment, gift, or hospitality to a third party to "facilitate" or expedite a routine procedure.

o   Ask, agree or accept a payment, gift or hospitality to or from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the Company in return.

o   Threaten or retaliate against another employee or worker who has refused to commit a bribery offense or who has raised concerns under this Policy or Company's Whistle Blowing Policy.

o   Engage in any activity in breach of this Policy.


·       Major Risk Areas of Bribery and Corruption
The major risk areas of bribery and corruption activities identified for the Company, employees and stakeholders include:

o   Gifts

o   Donations

o   Sponsors

o   Procurement and Tender

o   Payments

o   Recruitment and Promotion

o   Political Contribution


·       Compliance Training
All employees shall be provided required regular and appropriate compliance training relating to the Policy. New hires and recruits shall receive the training as part of their induction program. Company’s zero-tolerance approach to bribery and corruption shall be communicated to stakeholders at the outset of business relationship with them and as appropriate thereafter.


·       Supporting and Protecting the Employees who comply with Policy
The Company shall support and protect the employees who comply with the Policy and it shall be Company’s policy to ensure that employees who report in good faith are protected.


·       Reporting Violations
Employees and stakeholders of the Company shall report immediately any suspected or actual violations of this Policy or anti-bribery / anti-corruption laws. Complaints should be made in accordance with the guideline provided in 'Anti-Bribery Procedure' and 'Whistle Blowers Policy' of the Company.


·       Non-Compliance with the Policy
Employees who violate this Policy are subjected to disciplinary actions as per the Employees Handbook and other policies of the Company. Stakeholders who violate this Policy are subjected to penalty based on the severity of the case as defined in the blacklisting policy.


·       Monitoring and Review
This Procedure shall be reviewed one (1) year upon assessing the effectiveness and enforcement of the Policy.


— Approved by the Board of Directors on 15th October 2020




Anti-Bribery Procedure


Procedure Number: PRCD/2020/4



1. Purpose

The purpose of this Procedure is to outline the detailed procedure for the principles set out in the Anti-Bribery Policy to ensure that employees of STO Group (the “Company”) and stakeholders of the Company conduct business in an ethical manner and understand and adhere to the requirements of all applicable anti-bribery and ant-corruption laws and best practices.


2. Scope

This Procedure applies to all employees of the Company and other stakeholders that deal with the Company with respect to their activities, for or on behalf of the Company unless specified otherwise in their contract, appointment letter or any other guideline.

The Policy shall adopt standard guidelines on prohibition of corrupt practices in applicable antibribery laws, including the Penal Code of Maldives, Law on Prohibition and Prevention of Corruption in Maldives, U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act 2010 (“UKBA”) and is intended to make employees and stakeholders aware of their prohibitions in order to recognize potential problems and address them appropriately.


3. Procedure Overview

This policy shall guide the Company on deciding how much of its earnings shall be paid to its shareholders and in what form.


4. Procedures

Form of Bribery and Corruption

Offering or accepting any form of benefits mentioned below from Government Official and Commercial entities shall be prohibited to Company employees and stakeholders associated with Company.


·       A bribe is an inducement or reward offered, promised, provided, asked, agreed or received in order to gain any commercial, contractual, regulatory, business or personal advantage.

·       An inducement is something which helps to bring about an action or desired result.

·       A business advantage means that Company is placed in a better position (financially, economically, or reputationally, or in any other way which is beneficial) either than its competitors or than it would otherwise have been, had the bribery or corruption not taken place.


Kickbacks are payment of any portion of a contract made to employees of another contracting parties or the utilization of other techniques, such as subcontracts, purchase orders or consulting agreements, to channel payment to public officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.


Extortion means to directly or indirectly demand or accept a bribe, facilitation payment or kickback.

Prohibited Payments

Prohibited payments can take many different shapes and forms, but they typically involve a “quid pro quo”—that is, the payment will be offered or paid in exchange for some improper advantage or benefit. Prohibited payments include, but are not limited to, those designed to:

·       Induce the recipient to award a contract to the Company (even if in the end the Company is not awarded the contract);

·       Obtain advantageous treatment (for example, on tax, customs, permits, or licenses) that would not otherwise be available to the Company; or

·       Circumvent or cause non-enforcement of laws or regulations applicable to the Company.


Application of the Policy

Applicable anti-bribery and anti-corruption laws of Maldives prohibit Company, employees and stakeholders from giving, promising, offering and authorizing payment of anything of value to any government and private parties in order to obtain or keep business or to secure some other improper advantage. In essence, these laws prohibit the giving of anything of value to influence the party’s actions.

The prohibition on bribery and corruption applies to receiving or giving of anything of value, not only money. “Anything of value” may include, but is not limited to, the following:

·       Business opportunities;

·       Favorable contracts;

·       Cash, cash equivalents (e.g., gift cards, gift checks) or loans;

·       Payments for improper gifts, meals, travel and entertainment;

·       Favors, including offers of employment or internships;

·       Sponsorships;

·       Promises to pay/give;

·       Donations to a charity affiliated with or sponsored by a government and private parties; or

·       Political contributions.


Major Risk Areas of Bribery / Corruption and Exceptions


The Policy does not prohibit giving and receiving corporate gifts. However, gifts should be given and received within the guidelines provided in “Corporate Gift Policy”.


Company employees shall not accept cash as donations. Monetary or non-monetary contribution by the Company must adhere strictly to the requirements set out in the “Donation and Corporate Social Responsibility Policy” and “Donation and Corporate Social Responsibility Procedure”.


Any sponsor offered and received on behalf of the Company shall be in accordance with the guidelines and limitations provided in “Sponsor Policy”, “Sponsor Procedure” and “Corporate Social Responsibility Policy”.

Procurement and Tender

In order to carry out fair and transparent procurement and tender process and to build vendors / tenderers / suppliers confidence in the integrity of the Company procurement system, tender and bidding process shall be carried out in accordance with guidelines

and limitations provided in “Procurement Policy” and “Competitive Bidding Procedure”. The Company shall always encourage to comply with best practice to carry out procurement process.


The Company’s prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” (or expediting) payments. Facilitating payments refer to small payments to government officials or individuals to expedite or facilitate nondiscretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power or water service, or loading or unloading of cargo.

The Company shall not issue or release payments (payables) against the existing monetary and fiscal policies of the Company. Company employees shall refrain from accepting payments or any form of monetary benefits as gifts or whatsoever, in return of any transaction, from vendors and contractors / suppliers.

Recruitment and Promotion

Employees shall be recruited and promoted in accordance with “Human Resources Policy” and other relevant guidelines of the Company. The Company shall have a comprehensive “Recruitment Policy” with regard of all recruitments, including expatriates and skilled / non-skill labors.

The Company shall not hire or engage a government official, a private individual or his or her immediate family members, to improperly influence or gain unfair business advantage, or in exchange for any improper favor or benefit.

Political Contributions

The Company shall not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.


Controls and Risk Assessments

The company shall comply the control mechanism provided in Law No. 9/2014 (Penal Code of the Maldives) and Law No. 2/2000 (Prohibition and Prevention of Corruption Act) with regard to prevention and prohibition of Corruption.

Standard business risk assessments will be conducted on an annual basis to determine the level of controls necessary for a particular aspect of the Company’s operations, including in relation to major risk factor areas mentioned in this Procedure. The Risk assessments should give consideration to:

·       "business partnership risks", which includes risks deriving from relationships with or partnership with other Associated Entities;

·       "business opportunity risks", which includes the risk that pursuing or obtaining business opportunities may result in acts of bribery or corruption; and

·       "transactional risks", which includes an assessment of the risks associated with a business transaction undertaken by the Company or its Associated Entities.

Specific policies and procedures will be adapted and implemented to proportionately address the risks identified in this Procedure.


Protection and Secrecy of Reporting

Company aims to encourage openness and shall support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. No employees and stakeholders of the Company will suffer demotion, penalty, or other adverse consequences for refusing to engage in or permit a bribery offense or for raising concerns or for reporting possible wrongdoing, even if it may result in the Company losing business or otherwise suffering a disadvantage.

The Company has adopted a Whistle Blowers Policy which provides procedures for reporting violations of laws, rules, regulations or corporate policies. A copy of the Whistle Blowers Policy can be found on Company's intranet website at Stakeholders may find Company policies at

Employees and stakeholder / individuals whom report the and raise red flag on suspicious activities which may lead to corrupt practices in relation to business practices of the Company shall be provided legal protection. The Whistle Blowers Protection Act and Whistle Blowers Policy of the Company provide set principles to protect the anonymity of the person reporting the case of suspicious activities.



Failure to comply with this Procedure may result in severe consequences, which could include internal disciplinary action or termination of employment or contracts (in case of stakeholders) without notice. Violation of this Procedure may also constitute a criminal offense under the existing laws of Maldives. If it appears in the opinion of the Company that any employee or stakeholder of Company may have violated this Procedure and such laws, then the Company may refer the matter to the appropriate investigation authorities, which could lead to criminal investigations on the responsible person.


Monitoring and Review

Employees must adhere to Company's commitment to conduct its business and affairs in a lawful and ethical manner. All employees and stakeholders are encouraged to raise any queries with the Compliance Officer. The Compliance Officer shall monitor and ensure that the affairs and dealings of the Company are conducted within the umbrella of this Procedure.

This Procedure shall be reviewed one (1) year upon assessing the effectiveness and enforcement of the Policy.


— Approved by the Managing Director, and endorsed by the Board of Directors on 15th October 2020