Denver, Colorado

Anti-Corruption Compliance

  1. Introduction oAppsNET Partners, LLC is committed to conducting its business with integrity, transparency, and in compliance with all applicable laws and regulations. This policy outlines our commitment to preventing corruption, maintaining high ethical standards, and ensuring fair business practices in all our operations.
  2. Compliance with Anti-Corruption Laws oAppsNET Partners, LLC strictly prohibits any form of bribery, corruption, or unethical practices, whether involving government officials or private individuals, in any country where we operate. Employees must comply with the anti-corruption laws of the countries they operate in, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
  3. Gifts, Entertainment, and Hospitality a.
  • General Principles: Employees must exercise caution and good judgment when offering or accepting gifts, entertainment, or hospitality to or from customers, suppliers, government officials, or any other third party.
  • Approval Process: Any gifts, entertainment, or hospitality with a value exceeding $X must be pre-approved by [appropriate authority].
  • Record Keeping: All gifts, entertainment, or hospitality given or received must be accurately recorded in the company’s books and records.
  1. Payments and Commissions
  • Transparency: All payments made to third parties, including commissions, must be accurately recorded in the company’s books and records.
  • Due Diligence: Prior to engaging any third party, including agents and consultants, a due diligence process must be conducted to ensure they meet oAppsNET Partners, LLC’s ethical standards and comply with applicable laws.
  1. Reporting Violations Employees are encouraged to report any potential violations of this policy promptly through established channels without fear of retaliation. OAppsNET Partners, LLC will investigate all reported concerns thoroughly and take appropriate action.
  2. Training and Awareness
  • Training Programs: oAppsNET Partners, LLC will provide regular training on anti-corruption laws, business ethics, and compliance procedures to employees.
  • Communication: This policy will be communicated to all employees, suppliers, and relevant stakeholders to ensure awareness and understanding.
  1. Compliance Oversight
  • Monitoring and Review: The Compliance Committee will monitor compliance with this policy and periodically review its effectiveness.
  • Updates and Amendments: oAppsNET Partners, LLC reserves the right to amend this policy as necessary to ensure continued compliance with evolving legal requirements and business practices.
  1. Conclusion Adherence to this policy is mandatory for all employees and contractors of oAppsNET Partners, LLC. Employees who violate this policy may be subject to disciplinary action, up to and including termination of employment.
  2. Contact Information For questions or concerns regarding this policy, please contact

Last Modified: 8/14/2023