Zero tolerance, applied to ourselves first.

TenderPulse operates in the procurement sector. We sell software to firms participating in Bangladesh public procurement and donor-funded tendering. The integrity of every actor in that ecosystem matters — and ours is the integrity that matters most to us, because if we cannot maintain it, we have no standing to discuss anyone else’s.

This policy applies to every TenderPulse director, officer, employee, contractor, and intermediary acting on TenderPulse’s behalf. We hold ourselves to the most stringent of three frameworks: the UK Bribery Act 2010 (with its extraterritorial reach), the US Foreign Corrupt Practices Act, and the Bangladesh Anti-Corruption Commission Act 2004. UK Bribery Act 2010 Foreign Corrupt Practices Act Anti-Corruption Commission Act 2004

The following are absolutely prohibited:

• Offering, promising, or giving any financial or non-financial advantage to a public official to influence the official in their public function. UK Bribery Act 2010 §6
• Offering, promising, or giving any advantage to a private- sector counterparty to induce improper performance of a relevant function. UK Bribery Act 2010 §1
• Receiving or accepting any such advantage from a counterparty. UK Bribery Act 2010 §2
• Making facilitation payments — small payments to a public official to expedite a routine action. UK Bribery Act treats these the same as bribes. We do too.
• Engaging a third-party intermediary (consultant, agent, broker, partner) to do indirectly anything the policy prohibits us from doing directly. The act of failing to prevent bribery by an intermediary is itself a corporate offence under UK Bribery Act 2010 §7.
• Offering employment, contracting, or commercial benefit to a close family member of a public official as a route to influencing that official.
• Falsifying books, records, or invoices to conceal any of the above. Foreign Corrupt Practices Act books-and-records provisions.

Modest, transparent, customary business hospitality is permitted under our policy where it would not reasonably influence a procurement or commercial decision. The de minimis ceiling for gifts and hospitality without prior approval is BDT 5,000 per occurrence and BDT 20,000 per recipient per calendar year. Anything above either threshold requires written prior approval from the Compliance Officer.

Hospitality offered to public officials is strictly prohibited, regardless of value. We do not buy lunch, dinner, conference tickets, or travel for any procuring-authority employee, CPTU official, or BTRC representative. The cost of saying no in this context is much smaller than the cost of saying yes.

Gifts offered to TenderPulse staff are subject to the same ceilings. Gifts in excess must be declined or, where declining would cause offence, accepted with disclosure to Compliance and treated as TenderPulse property — typically donated to charity.

TenderPulse does not make political contributions of any kind — no donations to political parties, candidates, ballot committees, or political action committees. This applies in Bangladesh, in any other jurisdiction we operate in, and to any TenderPulse vehicle we may establish in the future.

We do not engage paid lobbyists. Where we have a substantive interest in a regulatory or legislative matter — for example, a draft Personal Data Protection Act consultation that affects how we operate — we engage through public consultation submissions and through industry-association channels (BASIS, BACCO) under our own name with our own positions disclosed.

Individual TenderPulse staff are free to make personal political contributions in their personal capacity, on personal time, with personal funds, with no implication that the donation reflects TenderPulse’s position. We do not reimburse, match, or coordinate any such activity.

Before engaging a third party who will act for or on behalf of TenderPulse — vendors, distributors, sales agents, consultants, M&A targets — we conduct risk-based due diligence. The enquiry covers ownership and beneficial-ownership disclosure, political-exposure status (PEP screening), sanctions list screening, prior debarment by the World Bank, ADB, or CPTU, and the firm’s own anti-bribery posture.

Our standard third-party contracts include: an anti-bribery warranty mirroring this policy, audit rights, and a termination right exercisable on credible suspicion of misconduct without penalty.

Where any TenderPulse staff member or third-party intermediary has a relationship with a public official that could be reasonably perceived as influencing TenderPulse’s procurement-side activities, the relationship must be disclosed to Compliance prior to the engagement and recorded in the conflicts register.

Every TenderPulse joiner completes anti-bribery training in the first week of employment. The training covers: this policy in plain language, the three statutes we operate under, common red-flag scenarios specific to procurement work in Bangladesh, how to refuse without causing offence, and how to escalate internally.

Refresher training is annual. Staff in commercial-facing roles (sales, customer success, partnerships) receive an additional quarterly scenario-based refresher.

Tone from the top: TenderPulse founders and senior leadership attend the training each year. We do not delegate this content to staff while exempting ourselves. Where leadership behaviour deviates from the policy, the policy applies first.

Reports of suspected misconduct go to help@tenderpulse.com.bd. Acknowledgement is sent within 48 hours. The matter is investigated by the Compliance Officer (or, where the Compliance Officer is implicated, by independent external counsel). Initial investigation outcome is communicated within 15 business days.

Where misconduct is confirmed, consequences include: termination of employment without notice, claw-back of any compensation obtained through the misconduct, civil action to recover losses, and referral to relevant regulators or law-enforcement authorities as appropriate. We do not insulate misconduct with severance packages, NDA gag-orders on victims, or quiet exits.

Whistleblower protection: any TenderPulse staff member, customer, or third party reporting in good faith is protected from retaliation. Retaliation is itself a separately disciplinable offence under this policy.