Anti-Bribery and Corruption Policy
Standards for honest business, responsible third parties, accurate records, and speaking up.
This policy sets required company standards. A product may be offered only when its applicable controls and provider arrangements are in place. It does not replace product-specific agreements or mandatory legal rights.
Scope and commitment
Turi Ventures LLC prohibits bribery and corruption in its business dealings, whether involving a public official, a private business, a customer, or an intermediary. This policy applies to managers, employees, contractors, agents, and third parties acting for the company. Applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act where relevant, must be considered alongside this company-wide standard.
Prohibited conduct
No person acting for the company may offer, promise, give, request, authorize, or accept money or anything of value to obtain an improper advantage or induce misuse of a role. Indirect payments, kickbacks, concealed commissions, sham contracts, job offers, favors, digital assets, gifts, and benefits for family members or associates are covered. A payment remains prohibited when routed through a partner or recorded under an innocent description.
Public officials and facilitation payments
Dealings involving public officials, state-owned or controlled businesses, public international organizations, political parties, or candidates require heightened care. The company prohibits facilitation payments intended to speed up routine governmental action, even where a narrow legal exception might otherwise be discussed. Staff must refuse and report such requests. A payment made under an immediate threat to personal safety must be reported as soon as safely possible and accurately documented; it is not a standing approval for future payments.
Gifts, hospitality, travel, and expenses
Benefits must have a legitimate business purpose, be lawful, reasonable, infrequent, transparent, and never tied to a favorable decision. Cash and cash-equivalent personal gifts are prohibited. Benefits involving public officials, travel, accommodation, or a sensitive decision require prior written approval by an independent authorized manager or compliance owner. Approval must record the recipient, purpose, value, timing, and legal assessment where needed. No unapproved monetary threshold is implied by this public policy.
Third-party due diligence
Before engaging agents, introducers, consultants, or business partners, the company must assess identity, ownership, reputation, qualifications, official connections, compensation, and the reason for the engagement. Contracts must describe actual services and appropriate anti-corruption commitments. Unsupported invoices, unusual payment destinations, success fees without a clear basis, secrecy requests, and refusal to disclose beneficial ownership require investigation. No payment may be approved solely on an intermediary’s assurance that local practice permits it.
Conflicts, donations, and political activity
Actual or potential conflicts of interest must be disclosed and managed through recusal or independent review where appropriate. Charitable contributions, sponsorships, and community support must not conceal personal benefits or improper influence. Political contributions on the company’s behalf require specific legal review and management authorization and must never be used to influence product or provider decisions improperly. Personal political activities must not be presented as company actions.
Accurate records and financial controls
Company records must reflect the true nature, recipient, and purpose of expenditure. False invoices, off-book funds, disguised cash withdrawals, and splitting expenses to avoid approval are prohibited. Procurement and payment controls must provide appropriate separation of duties and supporting evidence. These are company standards and do not imply that every statutory accounting provision applicable to a public issuer applies to this LLC.
Reporting, investigation, and non-retaliation
Report concerns promptly to support@turipay.com with the subject “Confidential ethics concern” and identify if the concern involves management so it can be routed for independent review. Use a safe contact method and omit sensitive credentials. Reports must be treated as confidential to the extent reasonably possible and investigated without a conflicted person controlling the outcome. Retaliation against a person raising a good-faith concern or assisting a lawful investigation is prohibited. Staff may also report directly to an appropriate authority.
Consequences and review
Confirmed violations may result in disciplinary action, termination of a business relationship, remediation, and referral or reporting where appropriate. Management must maintain training, review higher-risk engagements and payments, assess incident patterns, and update this policy at least annually or when relevant requirements change. A business benefit is never a justification for ignoring this policy.
Company and contact
Turi Ventures LLCRegistered in Wyoming, United States30 North Gould StreetSheridan, WY 82801, United Statessupport@turipay.comFor sensitive evidence, request an approved secure channel before sharing documents.
Reference materials
These official resources provide background. Requirements depend on the product, activity, and applicable law.
Management is responsible for assigning policy ownership, maintaining supporting procedures, reviewing these standards at least annually, and updating them when material requirements change.