ABC Compliance

Effective Date: February 6, 2023
Company: IT Globals Pvt. Ltd.
Contact:
πŸ“§ Email: info@itglobal.com.np
πŸ“ž Phone: 01-5913146 / 01-5913147
πŸ“ Address: IT Plaza, 5th Floor, Kamalpokhari, Kathmandu, Nepal

1. Purpose

This policy sets out IT Globals Pvt. Ltd.’s zero-tolerance approach to bribery and corruption. It outlines our obligations under global and local Anti-Bribery and Corruption (ABC) laws, and provides guidance on building a robust compliance culture across the company.

All employees, contractors, agents, consultants, and business partners must uphold the highest standards of integrity and comply with this policy.

2. Compliance Obligations

All representatives of IT Globals Pvt. Ltd. are required to understand and comply with the following anti-bribery and corruption laws:

  • U.S. Foreign Corrupt Practices Act (FCPA)

  • UK Bribery Act 2010

  • OECD Convention on Combating Bribery

  • Nepal’s anti-corruption laws and regulations

You must:

  • Never offer, authorize, give, solicit, or accept a bribe, whether directly or indirectly.

  • Implement and follow reasonable procedures and internal controls to ensure ABC compliance.

  • Conduct due diligence before engaging with third parties (vendors, agents, subcontractors, consultants).

  • Avoid working with individuals or entities involved in bribery, fraud, or other unethical activities.

3. Basic Principles of ABC Laws

ABC laws prohibit:

  • Offering or giving anything of value to government officials to obtain or retain business.

  • Receiving bribes or kickbacks in any form.

  • Falsifying financial records or books to hide illegal payments.

  • Partnering with third parties who engage in corruption, bribery, or fraud.

Clean books and transparency are non-negotiable.

4. Consequences of Violation

Violating this policy may result in:

  • Termination of contracts or employment

  • Legal action, fines, and reputational damage

  • Regulatory penalties including billions in fines for organizations involved in international misconduct

  • Cross-border investigations and enforcement under international treaties

IT Globals Pvt. Ltd. strictly enforces this policy with zero tolerance.

5. Elements of an Effective ABC Compliance Program

To ensure effective implementation and risk mitigation, we follow the following foundational principles:

1. Tone at the Top

Leadership must demonstrate clear and consistent support for anti-corruption initiatives.

2. Code of Conduct & Policies

A formal Code of Conduct and clear compliance policies must guide daily operations, internal controls, and disciplinary actions.

3. Oversight and Resources

Compliance personnel must have independence, authority, and sufficient resources to monitor and enforce this policy.

4. Risk Assessment

We regularly assess ABC risks related to our operations, clients, geographies, and business model.

5. Training and Communication

Employees and relevant third parties receive periodic training on ABC laws and internal expectations.

6. Disciplinary Measures and Incentives

Violations are addressed with clear disciplinary actions. Compliance and ethical behavior are embedded into performance evaluations and rewards.

7. Third-Party Due Diligence

We vet and monitor third-party partners to ensure their practices align with our standards and laws.

8. Reporting Mechanism

We maintain confidential reporting channels and prohibit retaliation against anyone who reports suspected misconduct.

9. Testing and Review

The program is periodically reviewed to ensure effectiveness and updated based on internal findings and external developments.

6. Tailoring Your Compliance Program

Every business is unique. As recommended by the U.S. Department of Justice (DOJ) and international bodies, our compliance efforts are customized based on:

  • Business size and scale

  • Industry and geographic risk

  • Types of services offered

  • Nature of partnerships and third-party exposure

We are committed to evolving this policy and program to reflect changes in our operations and the regulatory landscape.

7. Contact for Questions or Concerns

For questions, clarification, or to report concerns related to bribery or corruption, contact our compliance team:

πŸ“§ Email: info@itglobal.com.np
πŸ“ž Phone: 01-5913146 / 01-5913147
πŸ“ Office: IT Plaza, 5th Floor, Kamalpokhari, Kathmandu, Nepal