CloudNova Anti-Corruption & Anti-Bribery Policy

Version 1.0 – Effective April 2025

1. Policy Statement

CloudNova enforces a zero-tolerance approach to bribery, corruption, and facilitation payments in any part of our operations. This policy is binding for all employees and third parties representing CloudNova. We are committed to conducting all business fairly, legally, and transparently in accordance with:

  • The Nigerian Corrupt Practices and Other Related Offences Act

  • The U.S. Foreign Corrupt Practices Act (FCPA)

  • The UK Bribery Act

  • Salesforce Partner Code of Conduct and Anti-Corruption Standards

2. Definitions

  • Bribery: Offering or receiving anything of value with the intent to influence a business or governmental decision.

  • Facilitation Payment: Small, unofficial payments made to expedite routine actions—these are strictly prohibited.

  • Third Parties: Includes vendors, consultants, agents, resellers, and subcontractors.

3. Prohibited Activities

Employees and representatives must not:

  • Offer, give, solicit, or receive bribes or kickbacks.

  • Provide excessive gifts, hospitality, or travel meant to influence decisions.

  • Approve or process false invoices or unrecorded payments.

  • Use intermediaries to facilitate corrupt transactions.

4. Risk-Based Third-Party Engagement

  • Due diligence is mandatory for any third party, especially those interacting with government officials or clients in high-risk regions.

  • Agreements with vendors and contractors must include anti-corruption clauses.

  • Any suspicious behavior by a third party must be escalated.

5. Record-Keeping & Transparency

  • All financial records, invoices, expense reports, and gifts must be accurate, complete, and subject to audit.

  • No off-book accounts or secret payments are permitted.

6. Reporting & Whistleblower Protection

  • Suspected violations should be reported to [email protected].

  • CloudNova maintains full confidentiality and protection against retaliation for any whistleblower.

  • Investigations will be conducted promptly, fairly, and independently.

7. Enforcement

Violations of this policy may result in:

  • Disciplinary action (up to and including termination)

  • Legal proceedings under Nigerian or international law

  • Disclosure to Salesforce, which may affect CloudNova’s partnership status

8. Oversight

This policy is reviewed annually by the Compliance & Ethics Committee and updated as necessary to reflect legal and partnership standards.