1. Purpose

Lacuna Space Ltd is committed to conducting business with the highest standards of integrity and transparency. This policy outlines our zero-tolerance approach to fraud, bribery, and corruption.

2. Scope

This policy applies to all employees, officers, directors, consultants, contractors, interns, and third-party partners acting on behalf of Lacuna Space Ltd globally.

3. Definitions

  • Fraud: Any act of deception intended for personal or financial gain, including embezzlement, falsification of records, or theft.
  • Bribery: Offering, giving, receiving, or soliciting anything of value to influence a decision or gain an unfair advantage.
  • Facilitation Payments: Small, unofficial payments made to expedite routine government actions. These are strictly prohibited.

4. Policy Statement

Lacuna Space Ltd will not tolerate any form of fraud or bribery. All business must be conducted honestly and ethically. Bribes, kickbacks, or improper inducements of any kind are strictly prohibited, whether made directly or indirectly.

5. Responsibilities

  • Employees must report any suspected fraudulent or corrupt activities immediately.
  • Managers must foster an ethical culture and ensure compliance with this policy.
  • Compliance Officer (or designate) will investigate allegations and recommend appropriate actions.

6. Gifts and Hospitality

Gifts and hospitality must:

  • Be infrequent, modest, and transparent.
  • Never be offered or accepted to influence a decision.
  • Be recorded in the company’s gifts register.

7. Due Diligence

All third parties (suppliers, agents, consultants) must undergo due diligence to assess their risk level and commitment to ethical conduct.

8. Reporting and Whistleblowing

Employees are encouraged to report concerns confidentially via:

  • Company Slack Portal: Contact Line Manager
  • Email: rob@lacuna-space.com
    Reports will be investigated confidentially and fairly, with no retaliation against whistleblowers.

9. Consequences of Breach

Violations of this policy may result in:

  • Disciplinary action, up to and including dismissal.
  • Termination of contracts.
  • Legal action or reporting to authorities.

10. Training and Communication

Regular training will be provided to ensure awareness and understanding. This policy will be made available to all employees and relevant stakeholders.

11. Review and Monitoring

This policy will be reviewed annually and updated as required to ensure ongoing effectiveness.

Lacuna-Space-Anti-Fraud-and-Bribery-PolicyDownload