How we do business, and what we refuse.

Procurement teams ask a supplier four questions that are usually answered by four thin documents nobody reads: do you bribe people, do you trade with sanctioned parties, is there forced labour in your supply chain, and can somebody inside your company raise a concern safely. This is one statement that answers all four properly. It is a statement of our conduct and our commitments, not a certification, not an audit report, and not a claim to hold a compliance program larger than we are. Where a legal threshold for a formal published statement does not yet apply to us, this statement names the threshold and why it does not apply.

We prohibit bribery and corruption in every form, direct or indirect, by anybody acting for us. Nobody at Transglot may offer, promise, give, request, agree to receive or accept any financial or other advantage intended to induce or reward the improper performance of a function, whether the counterparty is a public official or a private person. That includes facilitation payments, which are prohibited without exception even where local practice tolerates them. We comply with applicable anti-bribery law including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act 2010. Business courtesies must be modest, infrequent, transparent, properly recorded and never offered around a live decision. Political donations are not made in the company’s name.

Our books and records fairly and accurately reflect our transactions. Nothing is recorded falsely, mislabelled, kept off the books or routed through a third party to disguise its purpose. Expenses are supported by documentation. We do not maintain undisclosed accounts. This is not merely a legal requirement under anti-bribery law: an accurate ledger is the control that makes every other commitment in this document checkable.

Anybody acting for us who has a personal, financial or family interest that could influence a business decision must declare it before the decision is taken and step out of it. That includes an interest in a supplier, a customer, a partner or a competitor. A declared conflict managed openly is ordinary; an undeclared one is a breach of this statement.

We comply with applicable economic sanctions and export control laws, including those administered by the United States Office of Foreign Assets Control and the Bureau of Industry and Security, by the United Kingdom, and by the European Union. We do not knowingly provide the Service to a person or entity on a restricted or denied party list, to one owned or controlled by such a party, or to a customer located in or ordinarily resident in a comprehensively sanctioned country or territory. Customers give the corresponding undertakings in clause 40 of the Terms of Service. Where we learn that a customer or a payment is caught by a restriction, we will suspend the account and take advice rather than proceed.

We do not tolerate slavery, servitude, forced or compulsory labour, child labour or human trafficking in our own operations or in our supply chain, and we will not knowingly do business with an organization that does. Our operations are small and almost entirely digital: our supply chain is cloud infrastructure, software vendors, professional services and payment processing, which is a comparatively low risk profile rather than a risk-free one. We assess a prospective supplier for its own published commitments where they exist, and we will investigate and act on a credible report about a supplier. We are not currently required to publish a statement under section 54 of the United Kingdom Modern Slavery Act 2015, because we do not meet the turnover threshold; this clause is what we say instead of nothing, and we will publish a formal statement when the threshold applies.

We pay lawfully, we do not withhold identity documents, we do not charge recruitment fees to workers, and we do not require anybody to work in unsafe conditions. We do not discriminate on the basis of race, ethnicity, national origin, religion, sex, gender, gender identity, sexual orientation, age, disability, marital status or any other protected characteristic, in hiring, in pay, in promotion or in whom we do business with. We expect the same of our suppliers and of anyone acting on our behalf.

We compete on the product. We do not fix prices, allocate markets or customers, rig bids, or exchange competitively sensitive information with a competitor. We do not obtain a competitor’s confidential information improperly, and we do not ask a new joiner to bring it with them. We describe our own product accurately, including its gaps, and we describe a competitor’s product accurately or not at all.

We pay the tax we owe where we owe it, we do not use artificial structures whose purpose is to avoid tax, and we cooperate with tax authorities. Customers are responsible for their own indirect taxes as clause 11 of the Terms of Service sets out, and we will provide the documentation a customer needs to account for them.

Anybody, inside or outside the company, may raise a concern about conduct that breaches this statement, the law, or our other policies. Write to hello@transglot.ai with "Ethics concern" in the subject and it will reach a founder. Say as much as you are comfortable saying, and you may raise a concern anonymously, though it is harder for us to investigate one we cannot ask questions about. We will acknowledge, investigate proportionately, and tell you the outcome where we can.

We will not retaliate against anybody who raises a concern in good faith, and we will not tolerate retaliation by anybody else. That protection applies whether or not the concern turns out to be well founded, and it applies to employees, contractors, customers, partners and suppliers. Retaliation is itself a breach of this statement. Where a person is entitled to protection under a whistleblowing law, including the EU Whistleblower Directive as implemented locally, nothing here limits that protection or requires them to come to us first.

We expect anybody acting for us or supplying us to meet the standards in this statement. Where a supplier publishes its own equivalent commitments we rely on them and record the reliance. Where a supplier will not give the commitment, or where we find a breach we cannot get remedied, we will end the relationship. Our subprocessors are subject to a written contract in addition to this expectation, as the Data Processing Addendum describes.

This statement is owned by the founders, who are the accountable persons for it, and it is reviewed at least annually and whenever a material change to the business or the law requires. There is no separate compliance department, because there is not yet a company large enough to need one. As the company grows, this clause is the one that will change first.

Questions about this statement, a supplier diligence questionnaire, or a specific commitment you need in a contract go to hello@transglot.ai. Security matters go to security@transglot.ai and data protection matters to privacy@transglot.ai.