Anti-bribery and anti-corruption

Updated: February 2019

How we conduct business

Aha! is committed to the highest standards of business conduct, which include compliance with legal and regulatory requirements. We have created this policy to explain what we do to comply with anti-bribery and anti-corruption laws including:

  • Canada’s Corruption of Foreign Public Officials Act
  • The UK Bribery Act of 2010
  • The US Foreign Corrupt Practices Act of 1977

Aha! expects that anyone conducting business on behalf of or representing Aha! will follow this policy.

What we expect of those representing Aha!

Aha! has a zero-tolerance approach to bribery and corruption. Aha! employees, contractors, and vendors may not give or receive any of the following while conducting business on our behalf:

  • Bribes: Aha! prohibits the exchange of any type of advantage (financial or otherwise) in return for a person either improperly performing their duties or improperly influencing any act or decision. This prohibition applies to individuals in both the public and private sectors.
  • Facilitation payments: Aha! does not allow the use of small, unofficial payments to secure or expedite a routine government action by a government official, regardless of local customs (e.g., issuance of permits, licenses, processing visas, or work permits).
  • Kickbacks: Aha! will not make payments in return for a business favor or advantage (e.g., discounts or other types of cash incentives).

We also prohibit our employees and contractors from making any contribution or providing any financial support to any political party, candidate, or charity on behalf of Aha! unless expressly approved through the Aha! Cares program which defines our volunteer work and charitable giving. This prohibition obviously does not prevent individuals from taking part in political activities or making charitable contributions on their own behalf.

We do not accept gifts and hospitality without prior approval

Any gifts or hospitality provided to customers, vendors, or Aha! must be reviewed and approved by the legal team before being given or accepted. Our legal team (legal@aha.io) is responsible for determining whether the gift or hospitality is reasonable and justifiable by considering the following:

  • Compliance with applicable law
  • Name of individuals/companies involved in the proposed exchange
  • Type of entity (public/private)
  • Items of proposed exchange (e.g., cash, discount, service)
  • Reason for, and appropriateness of proposed exchange
  • Individuals/companies relationship to Aha!
  • Is the proposed exchange to be conducted in the normal course of business? (i.e., without the intention of (or without a reasonable prospect of) influencing an improper business advantage or rewarding the provision of an improper advantage)
  • Whether an exchange previously occurred between the same individuals

Individual Aha! employees and contractors are prohibited from receiving any gifts or hospitality from customers and vendors (both current and prospective) without the legal team’s approval.

We are transparent in our compliance

Compliance is easiest for all parties if questions are asked before offering or accepting a gift. Customers, vendors, employees, and contractors should always contact the legal team (legal@aha.io) with a question or concern about the application of this policy or any potential exchanges. The following provides a few examples of the types of questions that the legal team could answer:

Aha!

  • My main contact at the customer just got married, can I send a gift?
  • The customer sent me this gift/discount/etc., what should I do?
  • A vendor offered us gift cards, can we accept them?

Customers and vendors

  • Can I send a discount to my contact at Aha! to use our service?
  • Can I send a gift to my contact at Aha! for helping us?

Any known, suspected, or suggested violations of this policy must be reported. The legal team will promptly investigate all reported violations and, if warranted, will collaborate with the leadership team on an appropriate response, including corrective action and preventive measures. Aha! will promptly report any violations of applicable law to appropriate regulatory authorities. The legal team will maintain a record of all determinations made as well as all reports (including receipt, investigation, and resolution).

Aha! encourages openness and will support anyone who raises genuine concerns in good faith under this policy — even if they turn out to be mistaken. Aha! is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting a good faith suspicion that an actual or potential bribery or other corruption offense has taken place (or may take place in the future). If anyone believes that they have suffered any such treatment, they should inform the legal team immediately. You can contact the legal team at legal@aha.io.

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