Anti-Bribery And Anti-Corruption Policy
Effective Date: January, 1, 2026
Purpose and Policy Statement
This Anti-Bribery and Anti-Corruption Policy establishes the standards and controls used by Afintrix Advisory Analytics LLC (“Afintrix,” “we,” “us,” or “our”) to prevent, detect, and address bribery, corruption, and improper influence in connection with its operations and engagements.
Afintrix is an advisory, analytics, and governance firm providing structured oversight, compliance, and financial analysis support. Afintrix maintains a zero-tolerance position with respect to bribery and corruption in any form.
Scope of Application
This policy applies to:
- All employees, contractors, officers, and authorized representatives of Afintrix
- All business activities, engagements, and communications conducted on behalf of the firm
- All interactions with clients, vendors, counterparties, regulators, and public officials
This policy applies regardless of geographic location and covers both domestic and international activities.
Definition of Bribery and Corruption
For purposes of this policy:
- Bribery means offering, giving, receiving, or soliciting anything of value with the intent to improperly influence a decision, action, or outcome.
- Corruption includes abuse of entrusted power for personal or organizational gain, including kickbacks, facilitation payments, improper inducements, or concealment of improper transactions.
Items of value may include money, gifts, services, favors, travel, entertainment, employment opportunities, or any other benefit.
Prohibited Conduct
Afintrix strictly prohibits:
- Offering or giving bribes or improper inducements
- Soliciting or accepting bribes, kickbacks, or improper benefits
- Making facilitation payments to government officials or private parties
- Using third parties to circumvent anti-bribery obligations
- Concealing or mischaracterizing transactions to disguise improper activity
- Retaliating against individuals who report suspected misconduct
No individual acting on behalf of Afintrix may engage in conduct that creates the appearance of improper influence.
Gifts, Hospitality, and Business Courtesies
Modest and infrequent business courtesies may be permitted only when all of the following conditions are met:
- The item is reasonable in value and appropriate in context
- The item is not intended to influence a decision or action
- The item complies with applicable laws and organizational policies
- The item is transparently recorded where required
Cash or cash-equivalent gifts are never permitted.
Third-Party Relationships
Afintrix applies appropriate due diligence to third parties, including vendors, consultants, and contractors, to assess bribery and corruption risk.
Engagements may be declined or terminated if a third party:
- Refuses to comply with this policy
- Presents elevated corruption risk without adequate controls
- Is subject to sanctions or enforcement actions related to bribery or corruption
Third parties acting on behalf of Afintrix must comply with applicable anti-bribery laws and contractual obligations.
Reporting and Escalation
All personnel are required to report suspected bribery, corruption, or improper conduct promptly. Reports may be made through established internal reporting channels or in accordance with the Whistleblower and Ethics Reporting Policy.
Reports are handled confidentially to the extent permitted by law. Retaliation against individuals who report concerns in good faith is strictly prohibited.
Recordkeeping and Controls
Afintrix maintains accurate and complete records sufficient to reflect transactions and engagements honestly and transparently. Records must not be falsified, altered, or used to conceal improper activity.
Documentation is retained in accordance with the Record Retention and Document Management Policy.
Training and Awareness
Personnel receive periodic training appropriate to their role regarding anti-bribery obligations, prohibited conduct, escalation procedures, and ethical expectations.
Enforcement and Disciplinary Action
Violations of this policy may result in disciplinary action, up to and including termination of employment or contractual relationships. Violations may also be referred to appropriate authorities where required by law.
Policy Review
This policy is reviewed periodically and updated as necessary to reflect changes in law, regulatory expectations, or firm operations.
