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Anti-Corruption Policy

Kash Global due diligence, anti-bribery, anti-fraud and anti-corruption compliance programme



Kash global has zero tolerance to any kind of bribery, fraud or corruption whether internal related to its staff or external concerning any of its partners, suppliers or contractors.  We are committed to operating ethically, fairly, honestly and with integrity in all our conducts and relationships in any country we operate.  Kash Global is committed to apply effective systems to deter bribery, fraud and corruption.


Kash Global will constantly embrace all anti-fraud, anti-bribery and anti-corruption regulations including the UK Bribery Act 2010 in relation to conduct both in the UK and abroad.  Kash Global realises that fraud, bribery and corruption are illegal and may result in an imprisonment of up to ten years in addition to a fine.  If our business is found to be involved in any fraud activity, we may be susceptible to unbounded fines, exclusion from public tendering and serious damage to our reputation.



This anti-corruption and anti-fraud policy applies to all Kash Global employees (permanent, temporary and fixed-term), trainees, seconded staff, consultants, contractors, casual staff, volunteers, interns, representatives, sponsors, third parties or any other people associated to Kash global including their staff within and outside the UK. 


In the course of this policy, third party includes any person or entity our company works with including clients, suppliers, contractors, representatives, advisors or government organisations and their personnel who will be expected to abide with at least a minimum level of anti-corruption provisions.


Explanation of bribery

Bribery is the act of taking, giving, offering or requesting something of value in order to influence the decision making process of an employee in relation to conducting his or her assigned obligations and responsibilities that result in gaining an any sort of advantage.  Bribery is unlawful and members of staff must not involve in any kind of bribery be it direct or through a mediator, in the UK or overseas.


Gifts and hospitality

Kash Global accepts normal and reasonable hospitality and kindness provision provided it does not violate the following procedures:

  • it’s not intended to influence the receiving party to gain any sort of business advantage or as a reward for a provided favour or benefit whether explicitly or implicitly;
  • it’s not offered with the expectation of a favour or benefit in return;
  • it is not in violation of UK laws or those of the country of operation;
  • it is not in the form of cash directly or indirectly through vouchers, gift cards or any similar forms;
  • it is appropriate in value and reason;
  • it is offered explicitly not discreetly; and
  • it is not in excess of £100.


When it’s sensitive to decline the gift (if, for example, it’s culturally or religiously offensive), it must be declared to the managing director who will assess the situation.  However, if the gift is deemed inappropriate by the managing director, it must be returned with explanation to the offering party in the nicest possible way.  Nonetheless, Kash global understands the differences in the provision of gifts and hospitality among different cultures, regions and religions and will evaluate any circumstance accordingly.  Best practice requires that giving and receiving of gifts are declared to the managing director and the aim of gift exchange is always considered.


Facilitation payments and inducements

Kash Global is utterly intolerable to any kind of facilitation payments or inducements.  We realise that facilitation payments are a kind of fraud that relates to influencing a government in a way that affects the performance of a legal duty.  We understand that inducements are basically conducted in return for a business benefit and we decline to make or accept them.    


However, in case avoiding a facilitation payment may put the safety and security of Kash Global employees or their families at risk, in such cases, they must:

  • keep any payment to the minimum;
  • request a written receipt stating the exact amount paid and reason for payment;
  • record the payment to file; and
  • report the incident to the managing director.


Political donations

Kash global will refrain from making any cash or non-cash contributions to political parties or politicians based on its realisation that this may be perceived as an endeavour to obtain an improper business benefit. 


Charitable donations

Kash Global embraces and supports all sorts of contributions to non-for-profit organisations including financial, service and knowledge donations and accepts to disclose all contributions it makes to social enterprises.  However, Kash global will always ensure that such donations do not violate any legal or ethical standards and they are not used in any fraud or unethical practices.  All donations must be approved by the managing director.


Employee responsibilities

Kash Global employees must make sure that they read, understand and observe the details of this policy and the provisions of any training or other anti-corruption and anti-fraud guidance made available to them.


All Kash Global staff members and those working under its jurisdiction have equal responsibility for eliminating, detecting and reporting any kind of bribery, fraud or corruption.  They should steer away from any conduct that may violate the provisions of this policy.


If any member of staff believes or suspects that any act of bribery, fraud or corruption has happened or is likely to happen in the future, they must notify the managing director.  Any violation of this policy will result in a disciplinary action against the concerned employee and may lead to dismissal or termination of contract for gross misconduct.   



Whistleblowing procedures

If any staff member is concerned about an act of bribery, fraud or corruption related to Kash Global, they are encouraged to raise their concerns at an as early stage as possible.  If they are not sure about their concern, they should discuss it with their line manager or the managing director.  Kash Global employees will be familiarised with the whistleblowing procedure so that they can communicate their concerns quickly and confidentially.


If an employee becomes a victim of bribery, fraud or corruption

Any Kash Global employee who is offered a bribery, requested to offer one or are suspicious the possibility of being in a fraudulent situation, he/she must notify their line manager or the managing director as soon as possible.



Kash global understands that whistle blowers may be concerned about the consequences of reporting a corrupt act and it will support them even in case the concern is not proved a valid case.  Kash Global will make sure that staff who decline a bribery or reject to offer one or to involve in any act of corruption or raise concerns about such acts do not suffer any detrimental consequences such as dismissal, disciplinary actions or unfavourable treatment.


Employees who believe they been subject to unfair treatment as a result of refusing to involve in an act of corruption or for reporting such and act, they must inform the managing director immediately.


Training and communication

All Kash Global employees will receive training on this policy part of their induction and will be formally requested to accept compliance with its provisions on an annual basis. 


Kash Global’s anti-bribery, anti-fraud and anti-corruption policy will be explicitly communicated to all its partners, suppliers, contractors and third parties on commencement of contractual relations and as necessary thereafter.


Kash Global will provide pertinent anti-corruption and anti-bribery training to its employees and people related to its operations whenever it believes that their ability to abide with the Bribery Act 2010 needs to be improved.  Kash global will request its partners, contractors and third parties to provide such training to their staff when a potential risk of experiencing corruption or fraud is identified.


Maintaining records

Kash Global will maintain detailed records of its financial transactions and payments and apply internal controls for clarity of the system.  We will disclose and maintain written records of amounts related to hospitality and gifts offered or received, and accept that hospitality and gifts are subject to managerial review.


Monitoring and reviewing

Monitoring the application of this policy and evaluating its appropriateness, sufficiency and efficiency is the responsibility of the managing director who will regularly review its implementation.  The internal bribery, fraud and corruption deterrence system is subject to regular auditing to ensure its effectiveness and proper application.


Staff are encouraged to communicate their feedback and improvement suggestions in regard to this policy to the managing director and improvements will be applied as appropriate.  This compliance programme does not constitute part of staff employment contracts and Kash Global may make changes whenever deemed necessary to improve its effective in the prevention of bribery, fraud and corruption.