The purpose of this policy is to explain how Orbit Money Inc (“We,” “Our”) adheres to keeping high ethical standards and safeguarding against allegations of potential bribery and corruption.
This policy applies to all of our employees, business partners and third parties. Likewise, anyone who works for Orbit Money Inc. and is considered high-risk or is exposed to such allegations will undergo additional training and support. We must do this to identify and prevent possible corrupt activities.
We are transparent in our operations and conduct them legally and ethically. Orbit Money Inc. does not tolerate nor justify bribery and corrupt activities regardless of the reason or purpose.
Orbit Money Inc. strongly believes acts such as bribery and corruption hurt society and restrict economic development.
Bribery is classed as a criminal offence, and corrupt acts expose our business and employees to prosecution, fines and imprisonment. Bribery is a corrupt act which can severely damage Orbit Money Inc.’s reputation as well as both the public and private sectors.
Bribery is classed as an offer, promise, giving, demanding, or accepting financial compensation. Similarly, it can also be seen as a reward for encouraging an illegal action that is unethical or breaches trust.
We define corruption as a misuse of authority or public power for private benefit. For the benefit of this policy, whether the involved parties are payees or recipients of an act of bribery or corruption is irrelevant.
A person being bribed is in a position to gain, retain or influence a company. Typically, this could involve granting a contract or disregarding compliance policies because of a specific agreement between the sender and receiver.
Irrespective of whether it is before or after a contract or when compliance procedures have been ignored, the action is still considered bribery.
Corruption and bribery can be committed by anyone. In particular:
In Canada and the countries, where Orbit Money Inc. operates, bribery is a criminal offence and if not a criminal offence, it can have severe outcomes.
Any actions of bribery in Canada can hold a company responsible for failing to implement the right procedures to discourage such acts. This also applies to the USA, U.K. and the E.U.
To ensure success, effective risk assessment is needed. Identifying and reducing risks that can lead to bribery or corrupt acts can help stop such acts. Local management should regularly review the vulnerability of every business unit to limit such risks and enable the implementation of the correct prevention procedures.
Often, the major offences which are associated with bribery or corruption involve inaccurate keeping of records. It’s essential that accurate records are kept of maintenance of books, audits and balances are constantly settled with customers, service providers, and other relevant parties.
Our records and financial reporting should be accessible and transparent; they must represent each fundamental transaction. Any false, misleading or inaccurate records will not be condoned, and have severe consequences for Orbit Money Inc
At any given time, it’s mandatory for our business, to keep an effective system of internal control and monitoring of our transactions. If our risk assessment process detects bribery or corruption, we will regularly devise procedures to help reduce it on an ongoing basis.
Every manager of Orbit Money Inc. should ensure that they are responsible for ensuring proper and effective risk assessment. In particular, taking the necessary steps to prevent acts of bribery and corruption. The main person who oversees preventing bribery and corruption is the Director of Orbit Money Inc
In terms of service providers or future business partners we anticipate signing correspondent MSB agreements with, it’s possible that our arrangements and agreements with service providers and business partners can potentially present Orbit Money Inc. with significant risks.
Such risks are calculated when a service provider or business partner has managed an activity on our behalf. Typical activities may include onboarding customers, delivering funds, and receiving funds.
Every service provider or business partner must have an anti-corruption policy that corresponds to our own policy.
If we identify or suspect certain bribery or corruption risks around our service providers and business partners, we need to take the following steps:
If we know or are certain that our service providers or business partners are involved or engaged in bribery or corruption practices, we will take the necessary steps to terminate our agreement or business relationships.
Gifts, entertainment and hospitality, including the receipt or offer of gifts, tokens of gratitude, and invitations to events or social gatherings, about matters related to Orbit Money Inc. The activities are acceptable if they only coincide with value and occurrence.
To help identify if these are acceptable, the following questions when it comes to gifts or entertainment must be asked:
If the response to any of the above questions is not right, there could be a risk involved which could damage our company.
Such acts are considered by us as bribery and corruption:
If we catch any of these acts, we will take the necessary steps to stop or rectify them. We will also terminate our relationship with the lead or cause of such acts.
Employees of Orbit Money Inc. or its business partners should never give or receive gifts from any government official or their close families or business associates. Orbit Money Inc. is aware in some cultures, gift-giving, receiving or exchanging is a cultural norm.
If you become subject to this type of situation, consult our compliance manager before proceeding. Sometimes, gift circumstances can be acceptable such as:
Orbit Money Inc. must maintain and review the gifts, entertainment and hospitality registers.
Irrespective of it being given, received or offered, any gift which meets or exceeds 100.00 CAD in value, or is less but accumulated to 200.00 CAD or more from the same source within 12 months, must be reported to the compliance manager and recorded in the register.
This policy must be implemented across all global operations for it to be effective while also taking into consideration the diverse cultural environments in which we operate. In particular, this may involve more focus on our operations to adapt certain sections of this policy, such as gifts, entertainment and hospitality, to ensure they are fair, appropriate, and applicable. Managers for our operations are responsible for reporting and confirming any local adaptations to this policy with the compliance manager.
Any individual who works with or on behalf of Orbit Money Inc. has a duty of responsibility to help protect, prevent, and report instances not only of bribery but also of any other suspicious activity or wrongdoing.
Orbit Money Inc. is committed to ensuring that all employees have a safe, reliable and confidential way of reporting any suspicious activity. Any information and assistance can only be beneficial to our company. The sooner action is taken, the better it is for the individual and Orbit Money Inc.
If any concern arises about a corrupt act of some kind that is being considered or carried out either within Orbit Money Inc., by any service providers, business partners or by any of our competitors, employees must report the issue to their manager, the compliance manager, or the director.
In case an incident of bribery, corruption or wrongdoing is reported, we will act immediately to evaluate the situation and decide on our next steps.
This policy may be revised and updated from time to time. The responsibility to enforce this policy lies in the compliance manager and department managers. They must establish an ongoing monitoring system to ensure compliance with this policy.