Anti-Bribery & Corruption Policy

Who does this policy apply to?

Everyone who works for MadeLabs or acts on our behalf: officers, employees, contractors and subcontractors, wherever they are.

That includes our engineers in South America and anyone who introduces business to us or represents us to a client. Each person is responsible for following it, and anyone unsure whether something is allowed should ask Nicholas Barger, our CEO, before acting.

Which laws does it follow?

The US Foreign Corrupt Practices Act (FCPA), US federal and state laws against commercial bribery, and the anti-corruption laws of every country where our people work.

The FCPA prohibits offering anything of value to a foreign official to win or keep business or gain an improper advantage, and it requires accurate books and records. Where local law is stricter than this policy, we follow local law. Where this policy is stricter, we follow this policy.

What counts as a bribe?

Anything of value offered, promised, given or accepted to improperly influence a decision. An offer is enough, even if it is refused or nothing comes of it.

“Anything of value” includes cash, gifts, meals, travel, entertainment, discounts, a job or internship for a relative, and a donation to a favoured cause. Paying through someone else is still paying.

A government official includes anyone employed by a government department or agency at any level, anyone working for a state-owned or state-controlled company, and anyone acting in an official capacity. We make no payments to officials to speed up routine government actions. Facilitation payments are banned outright, with no exception.

Are gifts and hospitality allowed?

Yes, when they are modest, occasional, openly given and clearly connected to the business, and never when they could influence a decision.

• Never give or accept cash or cash equivalents, such as gift cards.
• Never give or accept a gift or hospitality while the other party is deciding on a proposal, contract or payment involving us.
• Get approval from Nicholas Barger before offering anything of value to a government official.
• Record business gifts and hospitality accurately in our expenses.

What do we expect of third parties and subcontractors?

The same standard we hold ourselves to. We choose them on merit, pay only for documented, legitimate work, and end the relationship if they breach this policy.

We expect our engineers in South America and every subcontractor we engage to meet this same standard. We pay for work that is described on an invoice, at a price that fits the work, and we don't make payments to anyone other than the party who did it.

How do we keep our books and records?

Accurately and completely. Every payment and expense is recorded with a true description of what it was for.

We keep no off-the-books accounts, and no one may disguise a payment or split one to avoid a review.

How do you report a concern?

Tell Nicholas Barger, our CEO. If you are outside MadeLabs, use our contact page or call (888) 369-1330.

We will look into every report. No one will face retaliation for raising a concern in good faith, even if it turns out to be unfounded. Anyone who breaks this policy faces discipline up to and including dismissal, and a contractor or subcontractor who breaks it loses the work.