Anti-Corruption Policy

The Fine Print

Anti-Corruption Policy


The Cirqle is committed to conducting business in an ethical and transparent manner. This Anti-Corruption Policy (“Policy”) outlines The Cirqle’s stance on corruption and provides guidelines for employees, contractors, and partners to ensure compliance with anti-corruption laws and regulations.


This Policy applies to all employees, contractors, officers, and directors of The Cirqle (“Representatives”). It also applies to third parties, including vendors, partners, and agents acting on behalf of The Cirqle.

Policy Statement

The Cirqle prohibits all forms of corruption, bribery, kickbacks, and other unlawful or unethical financial practices.

Bribery: Representatives must not offer, give, request, or accept any form of bribe, kickback, or unlawful incentive to or from any person or organization, including government officials and private sector employees.

Gifts and Hospitality: Representatives may not offer or accept gifts or hospitality aimed at obtaining or retaining business advantages.

Facilitation Payments: The Cirqle does not allow “facilitation” or “grease” payments, which are small payments made to expedite routine governmental actions.

Third Parties: Due diligence must be conducted before engaging with third parties. Representatives must ensure that third parties adhere to this Policy.

Record-Keeping: All financial transactions must be accurately recorded in The Cirqle’s books and records.


Compliance: Representatives are responsible for understanding and complying with this Policy and any related procedures.

Training: Employees will be provided with training on this Policy as part of their induction and will receive periodic refresher training.

Reporting: Any suspicion of corruption should be reported immediately through the designated whistleblowing channels.

Monitoring and Review: The Compliance Team will periodically review and update this Policy and related procedures.


Failure to comply with this Policy may result in disciplinary action, up to and including termination of employment or contract, as well as potential legal consequences.

Approval and Review

This Policy is approved by the Board of Directors and will be reviewed annually or as needed to ensure its effectiveness.

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