1. Zero tolerance
ReptoState does not pay, offer, accept, or condone bribes, facilitation payments, or kickbacks of any kind, anywhere, regardless of local custom. This applies to all employees, contractors, directors, agents, and counter-parties acting on our behalf.
2. Gifts and hospitality
Modest, infrequent gifts and hospitality may be acceptable when they are transparent, proportionate, and clearly within normal business courtesy. They must never be offered or accepted to influence a decision.
- Anything above
{{ FOUNDER: gift_declare_threshold_rs }}in value must be declared to the Compliance Officer within 5 working days and recorded in our gifts register. - Anything above
{{ FOUNDER: gift_pre_approval_threshold_rs }}requires pre-approval from the Compliance Officer. - Cash, cash equivalents, and any gift to a public official require pre-approval regardless of value. Most are simply prohibited.
3. Third parties acting on our behalf
Agents, introducers, valuers, lawyers, marketing partners — anyone paid to act for ReptoState — must agree in writing to this policy before engagement. We will terminate the relationship if they breach it.
4. Dealings with public officials
Any non-routine payment, gift, hospitality, or favour to a public official — at SECP, SBP, FBR, the Land Registry, a tax inspector, a court official, or anyone else in government — must be pre-approved and logged. Routine, transparent, published fees (e.g. a filing fee paid into a government bank account) are fine.
5. Facilitation payments
No facilitation or "speed" payments are permitted. If you are asked for one, refuse and report it via the whistleblowing channel.
6. Training and reminders
All staff complete anti-bribery training on joining and again every {{ FOUNDER: training_cadence_months }} months. Completion is recorded by the Compliance Officer.
7. How to report a concern
Use the whistleblowing channel. Reports are received by an independent third party. There is a strict anti-retaliation guarantee.
Last reviewed: 2026-05-01
