Art. 1 Introduction
Committed to integrity, transparency and professionalism, Data Riders establishes this policy to guide and regulate the offering and receiving of gifts, presents and hospitality in all activities. This policy extends the commitments described in the Code of Ethics & Conduct and the Anti-Corruption Policy, ensuring our commercial and institutional relationships remain free from any conflict of interest or suspicion of bribery.
Art. 2 Objectives & scope
- Establish criteria for offering and receiving gifts, presents and hospitality.
- Prevent conflicts of interest, the appearance of improper advantages and any influence on impartial decisions.
- Apply to all employees, leadership, consultants, partners, suppliers and third parties acting in Data Riders' name.
- Cover commercial, institutional and public-sector relationships alike.
Art. 3 Important definitions
An item of symbolic or promotional value, typically bearing the giver's logo, given freely and with no expectation of reciprocity.
An item of greater individual value offered outside the symbolic range — subject to additional scrutiny.
Meals, travel, accommodation, events or entertainment offered in the context of a professional relationship.
Any person exercising a public function, including employees of state-owned enterprises, regulators and members of public commissions.
Value that does not influence decisions — typically promotional items of modest, publicly disclosed cost.
Art. 4 General guidelines
- Gifts and hospitality may be offered or accepted only when of symbolic value, occasional nature and aligned with legitimate business purposes.
- Consult leadership or Compliance before accepting or offering gifts/hospitality whenever there is any risk of misinterpretation.
- Gifts that exceed a symbolic value must be reported to immediate leadership, who will decide whether to accept, refuse, return, or share them per Compliance guidance.
- Excessive gifts or hospitality may be required to be refused, returned or shared internally.
- Avoid gifts or hospitality during sensitive moments — negotiations, contract renewals, tenders, audits or similar.
If you are uncertain, seek direction from your manager, director or the Compliance channel before offering or accepting. Documenting the consultation protects both you and the company.
Art. 5 Interactions with public agents
- Do not offer cash, gift cards or cash equivalents to public agents — ever.
- Do not offer hospitality disproportionate to the official event (e.g., travel, lodging, entertainment in excess of applicable rules).
- Do not use intermediaries, consultants or third parties to deliver gifts or hospitality to public agents.
Respect the specific rules of each jurisdiction and each public body. Where a public agency has zero-tolerance policies, they apply in full.
Art. 6 Responsibilities
- Every employee and partner is responsible for reading, understanding and applying this policy.
- Leadership validates offerings and receptions that fall outside symbolic parameters and escalates to Compliance when needed.
- Compliance keeps the policy up to date, provides training, handles the reporting channel and investigates cases.
Art. 7 Training & communication
Data Riders provides regular ethics and compliance training covering gift and hospitality rules, integrating public-sector specificities and sector standards such as TSM and The Copper Mark.
Art. 8 Reporting & investigation channel
Any suspected violation of this policy must be reported immediately via the company whistle-blowing channel. Whistle-blowers are protected against retaliation. Write to [email protected] with the subject "Gifts & Hospitality — Report".
Art. 9 Consequences for non-compliance
Violations may trigger disciplinary measures proportional to the breach — warnings, suspension, termination for cause, contractual termination with partners and suppliers, and when applicable, notification to authorities and civil or criminal proceedings.
Art. 10 Revisions & updates
This policy is reviewed periodically to incorporate legal updates and best governance practices, aligned with TSM and The Copper Mark standards.