• The REDBOX Anti-Bribery and Anti-Corruption Policy (“Policy”) emphasizes Redbox’s zero-tolerance approach to bribery and corruption. It establishes Redbox’s principles concerning applicable Anti-Bribery and Anti-Corruption Laws.
    • The policy provides information and guidance on how to recognize and deal with bribery and corruption issues.
    • It guides us to act professionally, fairly and with the utmost integrity in all our business dealings and relationships, wherever we operate.


    • The Directors of Redbox shall undertake a periodic review and update this Policy to reflect applicable law(s) and latest notifications released by the regulating authorities from time to time.
    • Any changes to this Policy shall be tracked and documented for future reference, and all changes shall be performed by the Directors.
    • The employees are responsible for implementing the principles outlined in this Policy and should ensure they use it to disclose any suspected concern or wrongdoing.
    • Any violation of this Policy may have significant consequences, including potential prosecution, fines and other penalties for improper conduct, as well as imprisonment and disciplinary action up to and including termination of the concerned.


    • The principles outlined in this Policy apply to all employees, vendors, sub-contractors, customers, and business partners worldwide.
    • In countries where there are more stringent applicable laws, regulations or industry codes, Redbox requires compliance with the most restrictive requirement. The principles set out in this Policy shall stand superseded in those specific countries.


      • Redbox prohibits all forms of bribery and corruption, whether involving, but not limited to, Government Officials or a private sector person or company and whether directly or indirectly.
      • Redbox conducts its business lawfully and ethically and expects everyone associated with it to conduct its business with integrity regardless of the existence of any local customs or traditions that may question integrity.
      • No employees shall ever:
        • Directly or indirectly offer or pay, or authorize an offer or payment, of money or anything of value to a government official, Healthcare Professionals, or any other person or entity (including in the private sector), which is:
        • Intended to influence the judgment of the recipient in exercising his or her job responsibilities, or
        • Intended to secure preferential treatment or an improper advantage for Redbox, or
        • Intended as gratification for the recipient having made a decision or acted in a way that benefited Redbox.
        • Directly or indirectly request or accept any money or item of value, which is:
        • Intended to influence the judgment or conduct of an employee in his or her job responsibilities, or
        • Intended as gratification for a decision or act in a way that benefits the person or entity giving the item of value.
      • All employees must avoid any activity that may lead to, or suggest that a Facilitation Payment or Kickback will be made or accepted by Redbox.
      • If any employee is asked to make a payment on behalf of Redbox, he/she should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided.
      • The employee should always ask for a receipt that details the reason for the payment. In case of any suspicion, concern or query regarding a payment, raise these with the Directors without delay or hesitation.
      • Employees should notify any “red flags” or potential “red flags” observed to the Directors as soon as possible; this should cover both actual or suspected conflict with the compliance principles, outlined in this policy.
      • Our responsibility is to conduct operations and activities in compliance with applicable Anti-bribery and Anti-Corruption Laws, which prohibits improper/unethical payments to Government Officials. Any payment or benefit conveyed to a GO must be fully transparent, adequately documented, and accounted for.
      • Redbox imposes special requirements, including determining whether a Government Official is a PIGO and if so, additional evaluation and approvals are required. Further data may also be needed when a transaction is proposed with a PIGO that can influence decisions.
        • Examples of decisions made by PIGOs include, but are not limited to:
        • approval of product registration or licenses or marketing authorizations,
        • approval of pricing or reimbursement of a product,
        • awarding public tenders for government sales or contracts
        • granting licenses or permits required to operate or conduct business (i.e., by regulatory agencies).
      • Employees should notify any “red flags” or potential “red flags” observed to the Directors as soon as possible; this should cover both actual or suspected conflict with the compliance principles, outlined in this policy.
      • When engaging in a cross-border transaction, employees must ensure compliance with local laws in the GO’s Home Country unless otherwise specified in this Policy.
      • The interaction or transaction also must be permitted in the initiating employee’s country and in the country where the interaction or transaction is reasonably expected to occur.
      • Redbox acknowledges that the exchange of nominal gifts and entertainment sharing is customary in many parts of the world during national, cultural and religious occasions.
      • The giving or receipt of gifts by employees is not prohibited if the following requirements are met:
      • No quid pro quo: There must always be a legitimate business purpose to support gifts related expenses. Customary gifts, meals, entertainment, travel or lodging, may never be given or received in return for a favour/favourable treatment.
      • It complies with all applicable Anti-bribery and Anti-corruption laws;
      • It is given under the brand name of Redbox, and not in the name of any employee;
      • It does not include cash or a cash equivalent (such as gift certificates or vouchers);
      • Considering, the reason and nature of the gift, it is of an appropriate type and value and given at an appropriate time;
      • It is given openly, not secretly; and
      • Gifts should not be offered to or accepted from, GO or representatives, or politicians or political parties without seeking the Directors’ opinion. The test to be applied is whether, in all the circumstances, the gifts, hospitality and entertainment are modest, desirable, reasonable, and not viewed as lavish regardless of actual monetary value and justifiable.
      • Employees cannot accept any gifts in cash or kind, except owing to customary or religious practices followed by any third party. Employees need to exercise professional judgment in identifying inappropriate, frequent or material gifts and entertainment and shall avoid the same to maintain integrity and independence.
      • This policy does not intend to prohibit typical and appropriate hospitality (offered and received) to or from third parties, only if employees or personnel of the third-party organisation offering the hospitality are in attendance. Employees may provide hospitality limited to meals, drinks and other such sustenance without prior approval if it is reasonable and justifiable in all the circumstances, taking into account reason and nature, appropriate type, value, given at an appropriate time, and not made to influence the third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.
      • Hospitality involving attendance at sporting events or private boxes at sporting events should not be offered or accepted without seeking the Directors’ prior approval.
      • We recognise that in relation to gifts and hospitality referred to above, what is considered acceptable will vary from country to country and from region to region and what may be expected and acceptable in one country/region may not be in another. In countries where there are specific limits of monetary value prescribed under local law or policies defined, employees should obtain prior approval from the business finance head and the business unit head. In countries with no specific limits of monetary value prescribed under local law or policies defined, employees should obtain prior approval from the business finance head, the business unit head and the Directors.
      • In case any employee receives or offers hospitality or a gift, it should be declared via a written record for review by the Directors.
      • When a payment is extorted by an imminent threat to the safety of an employee or his/her family members, the demanded payment may be made. However, once the immediacy of the situation has been resolved, the payment must be reported to the Directors, including information on the circumstances and amount of the payment. Any such payment always must be accurately and completely recorded in Redbox’s books and records.
      • Redbox personnel will not be in breach of this policy regarding any payment made for personal safety and security reasons. As far as possible, employees should only make any such payment after consultation with Directors. Where not possible, employees should report such payment subsequently.
      • Redbox may make charitable donations that are legal and ethical under local laws and practices.
      • No donation must be offered or made without seeking the prior opinion of the Directors. In their personal capacity, employees may make donations that are legal and ethical under local laws and practices.
      • Redbox recommends that all such donations or contributions are documented with a receipt.
      • We understand that various applicable anti-corruption and anti-bribery laws make Redbox responsible for our Business Partners’ acts and others acting on our behalf. Therefore, no Business Partner, acting on behalf of Redbox may engage in any activity that could be construed as bribery or corruption – whether using Redbox funds or their own personal funds or whether acting directly or through a middleman. Redbox expects all those acting on our behalf to abide by our ethics and integrity standards and, where necessary and appropriate, to follow our procedures.
      • While engaging with Business Partners, employees must ensure that they comply with Redbox’s Anti-Bribery and Anti-Corruption Policy.
      • If any employee becomes aware that a Business Partner is engaged in bribery or corruption, that employee should immediately report his/her concern following the procedure set out in the “REDBOX Whistle Blower Policy.”


    • Redbox is required to keep accurate books and records and to maintain internal controls to prevent and detect potential violations of our policies or applicable laws. Internal controls are processes that monitor compliance with the company’s policies. Redbox has appropriate controls to ensure that diligence is conducted, transactions adequately approved, the documentation received to support expenses, and interactions handled as required by our policies. Redbox shall also use proactive reviews, audits, and internal investigations to monitor compliance and identify any potential areas to enhance.
    • All employees must ensure that all Redbox payments and transactions, regardless of value, are recorded accurately with appropriate documentation. For example, in connection with every transaction, employees must ensure that all required pre-approval forms, questionnaires, self-assessments, agreements with Business Partners and expense reports, with supporting documents, are maintained and recorded correctly. These requirements also apply to every expense regulated by this policy, such as gifts, meals, travel or other permitted expense.
    • Always err on the side of including more information about a transaction or an expense, rather than less. The goal is to ensure that the Redbox’s books, records and accounts accurately and fairly reflect our transactions in reasonable detail. Transparency and completeness in our records help demonstrate our compliance with this policy and applicable laws and regulations. For example, submitting an expense voucher for a meal and failing to note that Government Officials attended the meal may be viewed as creating an inaccurate corporate record. Creating a paper trail through emails or other documents after an expense was incurred to give the appearance that the expenditure was pre-approved also may be viewed as creating an inaccurate corporate record or falsifying documents.
    • Suppose an employee realizes that he/she mistakenly failed to provide complete information about a transaction or expense. In that case, he/she must escalate it to his/her supervisor, or the Directors, immediately. Trying to hide this mistake or falsifying of records should be avoided by employees. It is best to be open and honest about the issue and work transparently with a supervisor to correct it properly in Redbox’s books and records. If an employee becomes aware that Redbox’s books and records do not accurately reflect a transaction or expense, they must immediately report this issue.
    • Records and documents generated in connection with the principles outlined in this policy, including, but not limited to, any diligence files and contracting documents, must be maintained and stored as appropriate.


    • All Redbox employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If they are unsure whether a particular act constitutes bribery or corruption, or if they have any other queries, employees should raise these with the Directors. Concerns should be reported by following the procedure set out in “Whistle-Blower” policy.
    • An employee who refuses to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. Redbox aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
    • Redbox will ensure that no one will suffer any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any employee believes that he or she has suffered any such treatment, they should inform the Directors immediately.


    • All exceptions to this policy must be approved by the Directors.