Anti-Bribery & Corruption Policy

1. Introduction & purpose

Trustpilot Group plc and its group companies (together referred to as "Trustpilot", "we", "our" or “us”) are committed to doing business in an honest and ethical manner.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity and transparency in all our business dealings and relationships wherever we operate in the world.

Bribery and corruption can expose Trustpilot, the people who work for us, and those we do business with, to severe civil and criminal liability, investigations, fines and penalties - as well as undermine our reputation and vision to be a universal symbol of trust.

Our position is clear: We do not engage in corruption and we don’t pay bribes, regardless of local custom or practice. The offer, payment, authorisation, solicitation and acceptance of bribes is unacceptable.

This Anti-Bribery & Corruption Policy (the "Policy") requires compliance with all applicable laws and regulations on bribery and corruption, including without limitation the UK Bribery Act 2010, the Danish Criminal Code, the U.S. Foreign Corrupt Practices Act, the Australian Criminal Code 1995 (Cth), the Australian Corporations Act 2001 (Cth) and relevant state and territory legislation in Australia.

The purpose of this Policy is to set out and explain the prohibitions against bribery and corruption in Trustpilot’s business practices, and reinforce our commitment to carrying out business globally with honesty and integrity.

2. Who is covered by this policy?

This policy applies globally to everyone who works for or on behalf of Trustpilot in any capacity, wherever they are located, including employees, officers, directors, workers, agents, contractors, consultants, representatives and business partners (together referred to as "you" or "your").

We also expect the people we do business with, including our customers and suppliers, to operate lawfully, ethically and with integrity, and share our commitment to responsible business practices.

3. Definitions

BriberyAnything of value that is offered, provided, authorised, requested or accepted in order to improperly influence a person’s actions or decisions for the purposes of gaining or retaining an advantage.

A bribe may be monetary or non-monetary, tangible or intangible. A bribe may take the form of, or be facilitated through:

  • payments of money

  • gifts and entertainment

  • kickbacks and favours

  • discounts and favourable contract terms

  • promises of a business opportunity

  • donations, contributions and sponsorships

  • use of property or assets at a discount or free of charge

  • overpayments to business partners

  • information or assistance

CorruptionThe misuse of power or position for personal gain.

EntertainmentAny activity received for free or less than market price, such as meals, travel, accommodation, sporting events, recreational activities and other hospitality.

Facilitation paymentAlso known as ‘grease’ payments, facilitation payments are typically small, unofficial payments made to public officials to speed up or secure the performance of routine governmental duties or actions that should ordinarily be carried out without having to make such payments — for example:

  • Issuing permits or licences

  • Processing visas or other official documents

  • Clearing goods through customs or handling cargo

GiftsAny items of value or benefits given at no cost to the recipient.

KickbacksA type of unofficial commission for preferential treatment or improper services received.

Public official

  • any officer, employee or representative of a state or a state-controlled or state-owned enterprise or entity;

  • any officer, employee or representative of any local, state, regional or national government institution, department, agency or ministry;

  • any person holding a legislative, administrative, judicial position or public function of any kind; and

  • any officer or representative of a political party, or any candidate for a political office.

4. Key prohibitions

  • You must not offer, give or authorise bribes of any kind, including facilitation payments, to any person in order to improperly influence their actions or decisions in order to gain or retain an advantage.

  • You must not request or accept bribes of any kind in order to obtain or maintain an improper advantage for someone else.

These prohibitions apply regardless of whether:

  • the bribe is made to or from a public official or private individual;

  • the bribe is made directly, or indirectly through a third party; and

  • the bribe is made before or after the advantage is obtained.

Even the mere act of offering, or attempting to give, a bribe is prohibited - whether or not the item of value is actually demanded or accepted by the intended recipient, or has the intended effect on them.

5. How we manage our anti-bribery and corruption risk

To manage our bribery and corruption risk, we implement a range of procedures and controls relating to:

  • gifts and entertainment;

  • dealing with public officials;

  • people we do business with;

  • donations;

  • record-keeping; and

  • speaking up.

5.1 Gifts and entertainment

This Policy does not prohibit the giving or accepting of reasonable and appropriate gifts and entertainment for legitimate purposes such as building business relationships, promoting our brand, or marketing or demonstrating our products and services.

However, careful consideration of when it is appropriate to give and accept gifts and entertainment is critical for avoiding actual, or perceived, bribery or corruption.

You must only give or accept gifts and entertainment that are:

  • in good faith, occasional, reasonable and appropriate;

  • a normal business courtesy; and

  • given openly and transparently, not secretly; and

You must not give or accept gifts and entertainment:

  • with the intent or prospect of influencing decision-making or other conduct;

  • with the intent of obtaining any improper or undue advantage;

  • which are reasonably capable of being regarded in any way as a bribe; or

  • in the form of cash.

When considering whether gifts or entertainment are appropriate, you must take into account:

  • any past, pending or future business or administrative matters that are within the recipient’s sphere of influence;

  • the timing, type, value and context of the gift or entertainment; and

  • whether it could create an actual or perceived conflict of interest, or could compromise impartiality, personal judgement or integrity.

Gifts and entertainment will not be appropriate if they are unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

You should not actively seek gifts and entertainment from third parties.

Registration and Approval thresholds

In addition to the above considerations, the following thresholds apply in relation to:

  • when you must record gifts and entertainment that are offered, received or declined in the Gifts & Entertainment Register; and

  • when you must seek prior approval from the Corporate Services team (Legal) to offer or accept gifts or entertainment.

Thresholds

Record in the Gifts & Entertainment register?

Prior approval from Corporate Services (Legal) required?

GIVING

Gifts & Entertainment offered by you/given by you

Below USD $75 per person on any one occasion

Not required

Not required

USD $75-199 per person on any one occasion

Yes, even if the intended recipient declines/rejects

Not required

USD $200+ per person on any one occasion or cumulatively within 12 months

Yes, even if the intended recipient declines/rejects

Yes, approval required before offering/giving

RECEIVING

Gifts & Entertainment offered to you/received by you

Below USD $75 per person on any one occasion

Not required

Not required

USD $75-199 per person on any one occasion

Yes, even if you decline/reject

Not required

USD $200+ per person on any one occasion or cumulatively within 12 months

Yes, even if you decline/reject

Yes, approval required before accepting

Approval from the Corporate Services team does not replace any budgetary or financial approvals that you may need for offering gifts and entertainment, which you should seek separately as required.

Gifts & Entertainment RegisterWhere required, you should use these forms to add an entry in the Gifts & Entertainment Register. Please provide full and accurate details when completing the forms:

5.2 Dealing with public officials

Dealing with public officials brings a higher risk of corruption, or the perception of corruption. You should be especially careful when communicating, exchanging gifts and entertainment, or providing assistance to public officials.

Facilitation payments

Trustpilot does not permit the use of facilitation payments of any kind, regardless of local custom, practice or expectations.

You are prohibited from making or authorising facilitation payments on Trustpilot’s behalf and should avoid any activity that might lead to, or suggest, that a facilitation payment will be made.

Any requests for facilitation payments must be reported immediately to Trustpilot’s Corporate Services team.

5.3. People we do business with

You must never authorise someone we do business with, or other third party, to engage in bribery or corruption on Trustpilot’s behalf.

To manage the bribery and corruption exposure associated with people we do business with we:

  • build compliance with this Policy into our contracting processes where appropriate; and

  • take a risk-based approach to screening and due diligence, appropriate to the type of business partner and nature of the relationship.

5.4 Donations

We do not seek to influence the political process by improper or corrupt means. To mitigate this risk, we do not allow donations or contributions towards any political campaign, political party, political candidate or any politically affiliated organisation.

We may make charitable donations or similar contributions that are legal and ethical under all applicable laws - but we never offer sponsorships, charitable contributions or investments in order to disguise a bribe, or to gain an improper business advantage.

No donations or contributions may be offered or made by or on behalf of Trustpilot without the prior approval of Trustpilot’s Chief Financial Officer.

Donations of any size offered or made by or on behalf of Trustpilot should be fully and accurately recorded in the Donations Register using this form.

5.5 Record keeping

To prevent the risk of bribes and kickbacks being given or received, all of Trustpilot’s business and financial records must fairly and accurately reflect the nature and substance of transactions involving Trustpilot. Secret, unrecorded or unreported transactions are prohibited.

You must:

  • not make false or misleading records, or fail to record payments by or to Trustpilot;

  • ensure that expenses claims are fully and accurately recorded and submitted in accordance with our policies; and

  • ensure all invoices relating to dealings with third parties are correct and submitted in accordance with our policies.

6. Failure to comply

Involvement in bribery and corruption can lead to Trustpilot and its employees being prosecuted under civil or criminal law, severe fines and penalties, and even imprisonment. We therefore take our legal responsibilities very seriously - both for your sake and ours.

Any employee that breaches this Policy will be subject to disciplinary action, up to and including termination of employment.

Similarly, any worker, agent, contractor, consultant, representative or other business partner working for or on behalf of Trustpilot that breaches this Policy will be subject to termination of the business relationship as well as any other legal and remedial actions available to Trustpilot.

7. Reporting breaches or concerns

You are responsible for ensuring compliance with this Policy and we expect you to report any suspected or actual breaches of this Policy to your manager, supervisor or through our Speaking Up channels.

Our Speaking Up platform is available to everyone covered by this Policy and includes the ability to report anonymously. We take these concerns seriously and handle them promptly.

We do not tolerate retaliation against anyone who speaks openly about conduct they believe is against this Policy — even if the concern isn’t substantiated, as long as they have not knowingly made a false report.

8. Exceptions

No deviations from this Policy will be permitted unless there are exceptional circumstances. All requests for exceptions must be made to Trustpilot’s Corporate Services team, which will assess and decide on each request. Exceptions will be registered by the Corporate Services team.

9. Changes to this policy

Trustpilot’s Corporate Services team is responsible for this Policy. This Policy will be reviewed at least annually. It may be amended at any time with the approval of Trustpilot Group plc’s board of directors.

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