Our Policies

Last updated: November 16, 2023

Anti-Bribery and Corruption Policy

Purpose and Scope

The Soul Kit Project is committed to conducting itself with integrity and the highest ethical standards. This Anti-Bribery and Corruption Policy ("Policy") is designed to prohibit all forms of bribery and corruption, and to ensure that The Soul Kit Project complies with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act ("FCPA") and the U.K. Bribery Act ("UKBA").

This Policy applies to all employees, representatives, agents, consultants, contractors, and other individuals who act on behalf of The Soul Kit Project.

Definition of Bribery and Corruption

Bribery is the offering, promising, giving, or authorizing of anything of value to any person, including government officials, employees of state-owned enterprises, or other individuals, in order to obtain or retain an improper advantage.

Corruption is the abuse of entrusted power for private gain. This includes, but is not limited to, bribery, embezzlement, extortion, and fraud.

Prohibited Activities

The Soul Kit Project prohibits all forms of bribery and corruption, including, but not limited to:

  • Offering, promising, or giving anything of value to any person to obtain or retain an improper advantage

  • Soliciting, accepting, or receiving anything of value to influence or reward a person's decision or actions

  • Making payments to third parties to conceal or facilitate improper payments

  • Engaging in any other activity that violates any applicable anti-bribery or anti-corruption law

Compliance with Laws and Regulations

The Soul Kit Project is committed to complying with all applicable anti-bribery and anti-corruption laws, including the FCPA and the UKBA. These laws prohibit bribery and corruption, and they require companies to implement effective internal controls to prevent and detect bribery and corruption.

Internal Controls

The Soul Kit Project has implemented a number of internal controls to prevent and detect bribery and corruption. These controls include:

  • A comprehensive anti-bribery and anti-corruption training program for all employees

  • A due diligence process for identifying and vetting third parties

  • A system for reporting suspected bribery and corruption

  • A disciplinary process for violations of this Policy

Reporting Concerns

Any employee, representative, agent, consultant, contractor, or other individual who has a concern about a potential violation of this Policy should report it immediately to the Compliance Officer. Reports can be made in person, by phone, or by email.

Consequences of Violations

Any employee, representative, agent, consultant, contractor, or other individual who violates this Policy may be subject to disciplinary action, up to and including termination of employment. The Soul Kit Project may also take legal action against individuals who violate this Policy.

Commitment

The Soul Kit Project is committed to conducting itself with integrity and the highest ethical standards. This Policy is a key part of our commitment to preventing and detecting bribery and corruption.

Policy Review

This Policy will be reviewed and updated on an as-needed basis to reflect changes in applicable laws and regulations.

Anti-Discrimination Policy

The Soul Kit Project is committed to providing a work environment that is free from discrimination and harassment. This Anti-Discrimination Policy ("Policy") prohibits discrimination and harassment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, national origin, disability, age, marital status, veteran status, or any other protected characteristic under applicable law.

This Policy applies to all employees, representatives, agents, consultants, contractors, and other individuals who act on behalf of The Soul Kit Project.

Contact Information

If you have any questions about these policies, please contact us.