Enablers Association Anti-Bribery and Anti-Corruption Policy

Version: 1.0
Effective Date: 1 January 2026
Approved by: Enablers Mission Circle
Questions? [email protected]

  1. Our Commitment

The Enablers Association is committed to conducting business ethically and with integrity. We do not tolerate bribery, corruption, or any improper payments to obtain or retain business. This policy applies to all Active Members, Associates, and anyone acting on behalf of the Association.

  1. Applicable Laws

Members must comply with:

  • Swiss Criminal Code (Articles 322ter-322octies)
  • UK Bribery Act 2010
  • US Foreign Corrupt Practices Act (FCPA)
  • EU anti-corruption directives
  • Local anti-corruption laws in countries where we operate
  • Client anti-corruption policies and Business Partner Codes of Conduct
  1. Prohibited Conduct

You must NEVER:

Bribes & Kickbacks:

  • Offer, give, promise, or authorize anything of value to improperly influence business decisions
  • Accept or solicit anything of value in exchange for improper business advantage
  • Make payments to secure favorable treatment, contracts, or project assignments
  • Offer commissions, referral fees, or other payments to client employees to secure business

Examples of Prohibited Conduct:

  • Paying a client procurement officer to select Enablers for a project
  • Offering expensive gifts to influence a client’s vendor selection
  • Accepting payment from a subcontractor in exchange for project assignments
  • Making cash payments to “expedite” government permits or approvals
  1. Gifts and Entertainment – Reasonable Business Courtesy

Permitted (within limits):

Modest gifts and reasonable business entertainment are acceptable when they:

  • Are transparent and properly documented
  • Are clearly business-related
  • Do not create obligation or expectation of favorable treatment
  • Comply with recipient’s organization policies

Monetary Limits:

  • Per occasion: CHF/EUR 100 maximum value
  • Annual per client contact: CHF/EUR 300 maximum aggregate value
  • Examples of acceptable: Business meal, modest promotional items, tickets to business conferences

Always Prohibited:

  • Cash or cash equivalents (gift cards, vouchers)
  • Luxury items (jewelry, designer goods, expensive electronics)
  • Personal services or favors
  • Entertainment of a sexual or inappropriate nature
  • Anything that could be perceived as an attempt to influence

Exception: Gifts/entertainment exceeding limits may be approved in advance by the Network Development Circle for legitimate business purposes with proper justification and documentation.

  1. Public Officials and Government Entities

Stricter Rules Apply:

When working with government entities or public sector organizations:

  • Lower threshold: CHF/EUR 50 per occasion maximum
  • Pre-approval required for any gift or entertainment to public officials
  • Extra scrutiny: Government officials cannot request or suggest gifts/entertainment
  • “Public official” includes: government employees, political candidates, employees of state-owned enterprises, public university staff

Important: Even small courtesies can violate anti-corruption laws when public officials are involved. When in doubt, seek pre-approval.

  1. Facilitation Payments

Facilitation payments (small payments to government officials to expedite routine services) are prohibited unless pre-approved by the Network Development Circle.

If you believe a facilitation payment may be necessary:

  1. Contact [email protected] immediately
  2. Document the request and circumstances
  3. Obtain written pre-approval before making any payment
  4. Retain all documentation
  1. Client Anti-Corruption Policies

When working on client projects:

  • Review and comply with the client’s Business Partner Code of Conduct or equivalent policy
  • If client policy is stricter than this policy, follow the client policy
  • If uncertain about client requirements, contact the Client Responsible Member or [email protected]
  1. Due Diligence and Red Flags

Be alert for warning signs:

  • Requests for cash payments or payments to third parties
  • Unusually high commissions or fees requested
  • Refusal to provide proper documentation or invoices
  • Requests for false invoices or backdated documents
  • Involvement of agents or intermediaries with unclear roles
  • Requests to conceal identity of parties involved

If you encounter red flags: Stop and report to [email protected] before proceeding.

  1. Record-Keeping and Documentation

All gifts, entertainment, and business expenses must be:

  • Accurately recorded in expense reports or financial records
  • Supported by receipts and documentation
  • Clearly described with business purpose and participants
  • Available for audit or review

No off-the-books accounts. All transactions must be properly documented in Association or member financial records.

  1. Reporting Obligations

You must report to [email protected] if you:

  • Are offered a bribe or improper payment
  • Witness or suspect bribery or corruption
  • Are asked to make an improper payment
  • Are unsure whether conduct complies with this policy
  • Encounter the red flags described in Section 8

Timeline: Report immediately (within 24 hours) upon discovery.

No retaliation: The Association prohibits retaliation against anyone who reports suspected violations in good faith.

  1. Approval Process for Borderline Cases

When uncertain about compliance:

  1. First Contact: Email [email protected] with:
    • Description of proposed gift/entertainment/payment
    • Value and business purpose
    • Recipient information (name, organization, role)
    • Why you believe it may be appropriate
  2. Review: Compliance Contact consults with Network Development Circle
  3. Decision: Network Development Circle may:
    • Approve (with documentation requirements)
    • Deny
    • Request decision from Enablers Mission Circle for complex cases
  4. Timeline: Response within 3 Working Days for routine requests; complex cases may require additional time
  5. Documentation: All approvals must be in writing and retained for 6 years
  1. Consequences of Violations

Violations of this policy may result in:

  • Personal criminal liability and fines under Swiss, EU, US, or other laws
  • Liability to the Association under Member Agreement Section 14a
  • Termination of membership or project assignment
  • Damage to the Association’s reputation and client relationships
  • Legal costs and penalties to the Association

This is serious: Bribery and corruption violations can result in substantial fines and imprisonment under applicable laws.

  1. Training and Awareness
  • All new Active Members and Associates must acknowledge this policy upon joining
  • Annual policy review and acknowledgment required
  • Members working on high-risk projects (government, high-value contracts) may receive additional training
  • Contact [email protected] with questions
  1. Policy Review

This policy will be reviewed annually by the Network Development Circle and updated as needed to reflect changes in law or Association operations.

Quick Reference: When in Doubt

Before accepting or offering anything of value, ask:

  1. Is it transparent? (Could it be openly disclosed?)
  2. Is it reasonable? (Within CHF/EUR 100 limit?)
  3. Is it proper? (No expectation of favorable treatment?)
  4. Is it compliant? (Client policies, applicable laws?)

If “no” to any question → Contact [email protected]

Acknowledgment: I have read and understood the Anti-Bribery and Anti-Corruption Policy and agree to comply with it.

Member Name:           _______________
Signature:                    _______________
Date:                           _______________