Effective Date: October 2026
This Policy states Chainstack Pte. Ltd.’s public commitment to preventing bribery and corruption in every market where we do business.
Chainstack Pte. Ltd. (“Chainstack”, “we”, “us” or “our”) conducts business ethically, transparently and in compliance with applicable anti-bribery and anti-corruption laws. We do not tolerate bribery, corruption, kickbacks or other improper benefits in connection with our business.
This Anti-Bribery & Anti-Corruption Policy (the “Policy”) explains the standards expected of persons acting for or on behalf of Chainstack and the principles we apply to prevent, identify and address bribery and corruption risks.
This Policy applies to all Chainstack directors, officers, employees, contractors, consultants, agents, intermediaries, representatives and other persons acting for or on behalf of Chainstack (together, “Covered Persons”).
We also expect suppliers, resellers, referral partners and other business partners to comply with applicable anti-bribery and anti-corruption laws and to follow standards consistent with this Policy when working with Chainstack.
Chainstack complies with applicable anti-bribery and anti-corruption laws, including the Singapore Prevention of Corruption Act 1960 and, where relevant to our activities, laws with extraterritorial effect such as the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010.
Where local law establishes a stricter standard than this Policy, the stricter standard applies. No commercial objective, business opportunity or instruction justifies conduct that violates applicable law or this Policy.
Covered Persons must not directly or indirectly offer, promise, authorize, give, request, agree to receive or accept anything of value for an improper purpose. Prohibited conduct includes seeking to influence a decision, obtain or retain business, secure preferential treatment, avoid a lawful requirement or reward improper conduct.
A bribe does not need to involve cash. Anything of value may constitute an improper benefit, including:
An offer, promise or request may violate this Policy even if it is rejected or does not produce the intended result. Covered Persons must not use another person to do anything that Chainstack could not lawfully or ethically do directly.
Dealings with Public Officials present heightened risk. A Public Official includes government officers and employees, persons acting for government agencies, officers and employees of state-owned or state-controlled enterprises, political party officials, candidates for public office and officers or employees of public international organisations.
Covered Persons must not offer or provide anything of value to a Public Official to influence official action or obtain an improper advantage. Any legitimate benefit involving a Public Official must be lawful, reasonable, proportionate, transparent and connected to a genuine business purpose.
Reasonable and proportionate gifts, meals, hospitality and entertainment may support legitimate business relationships. They must never be used to influence a decision improperly or create an actual or perceived obligation.
A gift or hospitality may be offered or accepted only when it is lawful, appropriate in the circumstances, reasonable in value and frequency, connected to a legitimate business purpose, not provided in cash or cash equivalents, and consistent with Chainstack’s applicable approval and recording requirements.
Particular care is required during tenders, procurement processes, contract negotiations, regulatory proceedings or other situations in which the recipient is expected to make or influence a decision affecting Chainstack.
Chainstack prohibits facilitation or “grease” payments, kickbacks, secret commissions and similar arrangements. Covered Persons must not make or authorize a payment or benefit to secure or accelerate routine government action, obtain favourable treatment or reward the improper influence of a business decision.
If a payment is demanded because of an immediate and credible threat to a person’s health, safety or liberty, personal safety comes first. Any payment made in those circumstances must be reported to Chainstack as soon as reasonably practicable and accurately recorded.
Chainstack may be responsible for improper conduct carried out by third parties acting for or on its behalf. We therefore apply risk-based review and oversight to agents, consultants, intermediaries, resellers, referral partners and other third parties where the relationship presents an elevated bribery or corruption risk.
Warning signs may include excessive or unusual fees, requests for cash or payments to unrelated persons or jurisdictions, unclear ownership, vague invoices, refusal to provide compliance information, close relationships with decision-makers, insufficient qualifications or credible allegations of misconduct.
Chainstack will not engage or continue to engage a third party where there is reason to believe that the third party may participate in bribery or corruption connected with Chainstack’s business. Payments must correspond to legitimate, documented services and be reasonable for the work performed.
Charitable contributions and sponsorships must serve legitimate purposes and must not be used to influence a decision, obtain or retain business, secure an improper advantage or disguise a prohibited payment.
Chainstack does not make any political contributions unless they are expressly authorized in accordance with applicable law and internal approval requirements. Individuals may participate in lawful political activity in their personal capacity and using their own resources.
Covered Persons must avoid situations in which personal, financial or other interests improperly influence, or could reasonably appear to influence, their judgment on behalf of Chainstack. Actual or potential conflicts connected with Chainstack business must be disclosed promptly through the applicable internal process.
Chainstack maintains books and records that accurately and fairly reflect its transactions and the disposition of its assets. Transactions and expenses must be properly authorized, accurately described and supported by complete documentation.
Covered Persons must not create undisclosed or unrecorded funds or accounts, make false or misleading entries, use vague or inaccurate invoices, or disguise the nature of a payment or expense. Applicable financial approvals and internal controls must be followed.
Covered Persons should promptly report actual, suspected or attempted bribery, corruption or other violations of this Policy to their manager, Chainstack Legal or another reporting channel designated by Chainstack. Reports should provide enough information for Chainstack to understand and assess the concern.
Reports may be made confidentially and, where permitted and available, anonymously. No person should investigate suspected misconduct independently where doing so could compromise evidence, confidentiality or an official investigation.
Chainstack prohibits retaliation against anyone who in good faith raises a concern, refuses to participate in conduct they reasonably believe may violate this Policy or applicable law, or assists with an investigation. A good-faith report will not result in adverse action merely because the concern is not substantiated.
Chainstack assesses reported concerns and may conduct an investigation where appropriate. Covered Persons are expected to cooperate fully and honestly with investigations conducted by or on behalf of Chainstack.
Chainstack may refer suspected unlawful conduct to competent authorities where required or appropriate and will cooperate with lawful requests from regulatory, investigative and law enforcement authorities.
All Covered Persons are responsible for understanding and complying with this Policy. Managers are expected to promote integrity, help persons under their supervision understand applicable requirements and escalate compliance concerns appropriately.
Chainstack may provide anti-bribery and anti-corruption training based on role and risk exposure. Persons working in sales, business development, partnerships, finance and other higher-risk functions may be required to complete periodic training.
Violations may expose individuals and Chainstack to serious legal, financial and reputational consequences. A violation may result in disciplinary or other appropriate action, up to and including termination of employment or consulting engagement, subject to applicable law. Chainstack may also suspend or terminate relationships with third parties that violate applicable law or the principles of this Policy.
Chainstack Legal provides guidance on the interpretation and application of this Policy and may establish supporting procedures and guidance. Questions about whether proposed conduct is permissible should be raised before the relevant action is taken.
This Policy should be read with Chainstack’s other applicable policies, procedures, contractual requirements and compliance standards, including sanctions and trade compliance requirements. Where another applicable requirement establishes a higher standard, the higher standard should be followed.
Chainstack may review and update this Policy from time to time to reflect changes in applicable law, regulatory guidance, business activities and compliance risks.
Questions or concerns regarding this Policy may be raised with Chainstack Legal at [email protected] or through the reporting channels designated by Chainstack.
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