top of page

ANTI-CORRUPTION &
BRIBERY POLICY

1. Introduction GlobalFineArts is committed to conducting its business with integrity, transparency, and accountability. We have a zero-tolerance approach to bribery and corruption and are dedicated to complying with all applicable anti-corruption laws, including but not limited to the UK Bribery Act, the U.S. Foreign Corrupt Practices Act (FCPA), and local regulations where we operate.

​

2. Scope This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other third parties acting on behalf of Starmuseum. It covers all business dealings and transactions in all countries where we operate.

​

3. Definition of Bribery and Corruption

  • Bribery: Offering, giving, receiving, or soliciting something of value to influence an outcome improperly.

  • Corruption: Abuse of power for personal or organizational gain.

  • Facilitation Payments: Small, unofficial payments to speed up routine government actions.

​

4. Prohibited Conduct

  • Bribes and Kickbacks: Employees must not offer, promise, give, or accept bribes or kickbacks in any form.

  • Gifts and Hospitality: Modest gifts and hospitality are permitted only if they are reasonable, transparent, and not intended to influence a business decision.

  • Charitable Donations and Sponsorships: Contributions must not be used as a substitute for bribery or to gain an improper advantage.

  • Political Contributions: GlobalFineArts does not make political donations to any party, candidate, or campaign.

​

5. Responsibilities

  • Employees and third parties acting on behalf of Starmuseum must uphold this policy and report any suspected violations.

  • Managers must ensure their teams understand and comply with this policy.

  • The compliance team is responsible for monitoring and enforcing this policy.

​

6. Reporting and Whistleblowing Anyone who suspects or becomes aware of a violation of this policy must report it immediately via the designated whistleblowing channel. Reports will be treated confidentially, and whistleblowers will be protected against retaliation.

​

7. Training and Awareness GlobalFineArts provides regular anti-corruption training to employees and relevant third parties to ensure awareness and compliance with this policy.

​

8. Consequences of Non-Compliance Violations of this policy can result in disciplinary action, including termination of employment, termination of contracts, legal action, and criminal prosecution.

​

9. Review and Updates This policy will be reviewed periodically and updated as necessary to comply with evolving legal and ethical standards.

bottom of page