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Governance · Anti-Bribery & Anti-Corruption
No improper advantage.No hidden influence.No exception.
LDV Groove’s intended anti-bribery and anti-corruption framework is designed to prevent improper payments, gifts, influence and concealed benefits across commercial relationships, public-sector interactions, tenders, sourcing, distribution and international expansion.
Zero Tolerance
No bribes or kickbacks
No Facilitation
No unofficial speed payments
Prior Approval
Gifts and hospitality controlled
Due Diligence
Know third parties
Speak Up
Concerns raised without retaliation
Our Anti-Corruption Principle
Business must be won through value, capability and trust—not improper influence.
No employee, director, agent, distributor, adviser or other representative should offer, promise, give, request or accept anything of value to obtain an improper advantage, influence a decision or reward conduct that should remain independent.
01
Direct or Indirect
The prohibition applies whether a benefit is provided personally or through an intermediary, supplier, consultant, relative, charity or connected party.
02
Public or Private
Improper influence is unacceptable in government dealings, commercial transactions, tenders, sourcing, hiring, distribution and customer relationships.
03
Cash or Non-Cash
Risk may arise through money, gifts, travel, hospitality, rebates, commissions, jobs, donations, discounts, confidential information or other benefits.
04
Results Never Excuse Conduct
Sales, approvals, contracts, licences, customs clearance, market access or delivery pressure do not justify improper payments or concealed arrangements.
Core rule: If a payment, gift, favour or arrangement would be embarrassing if disclosed to the board, customer, regulator or public, it should not proceed without immediate review.
Governance & Accountability
Responsibility follows authority, influence and control.
The intended governance model combines leadership oversight, functional controls, business ownership and individual accountability, with higher scrutiny for public officials, tenders, cash payments, high-risk countries and third-party intermediaries.
01
Board & Leadership
Set the tone, approve the framework, provide resources and receive reporting on material allegations, breaches and remediation.
02
Finance, Legal & Compliance
Design approval controls, review high-risk arrangements, protect accurate books and support investigation and remediation.
03
Business & Entity Leaders
Assess local risks, supervise third parties, document decisions and stop transactions when red flags remain unresolved.
04
Every Representative
Refuse improper requests, follow approval rules, maintain truthful records and raise concerns promptly.
Prevention & Response Lifecycle
A disciplined process from first red flag to verified closure.
Controls should operate before a benefit is offered or a third party is appointed—not only after an allegation or financial loss occurs.
01
Prohibit
Define conduct that is never acceptable, including bribes, kickbacks and facilitation payments.
02
Assess
Evaluate the recipient, purpose, value, timing, geography, decision context and third-party role.
03
Approve
Obtain documented authority before higher-risk gifts, hospitality, sponsorships, travel or intermediaries.
04
Record
Maintain accurate descriptions, invoices, recipients, business purpose, approvals and supporting documents.
05
Monitor
Review unusual payments, commissions, tender activity, third-party changes, complaints and repeat exceptions.
06
Respond
Escalate, preserve evidence, investigate fairly, stop exposure and verify remediation to closure.
Anti-Bribery Risk Universe
Improper influence often hides inside ordinary business activity.
The categories below help teams recognise situations that need prohibition, approval, enhanced diligence or escalation.
01
Gifts & Hospitality
Cash equivalents, lavish meals, travel, entertainment, personal benefits or repeated courtesies intended to influence a decision.
02
Facilitation Payments
Unofficial payments to speed routine government action, customs handling, permits, inspections, utilities or other services.
03
Agents & Intermediaries
Unclear services, excessive commissions, offshore accounts, political connections, refusal to disclose ownership or requests to avoid contracts.
04
Tenders & Procurement
Gifts to decision-makers, confidential bid information, collusion, undisclosed relationships, side agreements or unofficial access.
05
Donations & Sponsorships
Charitable, community or promotional payments connected to officials, customers or decision-makers without transparent purpose and review.
06
Travel, Expenses & Rebates
False expenses, personal travel, inflated invoices, hidden discounts, credit notes or rebates used to transfer value improperly.
07
Books & Records
Vague descriptions, split invoices, off-book funds, false vendors, unsupported cash withdrawals or payments recorded under misleading accounts.
08
Conflicts & Related Parties
Undisclosed ownership, family relationships, personal interests or outside businesses that affect selection, pricing, hiring or approval.
High-Risk Payment Gate
01
Clear business purpose
Specific, legitimate and documented
Required
02
Verified recipient
Identity, ownership and role confirmed
Required
03
Reasonable value
Proportionate to genuine services
Required
04
Approved payment route
Contracted account, invoice and evidence
Required
05
No unresolved red flags
No cash, secrecy, side payment or influence
Required
Public Officials, Tenders & Market Access
The closer the transaction is to public authority, the stronger the control.
Interactions involving regulators, customs, licensing authorities, state-owned enterprises, public procurement or politically exposed persons require careful identification, lawful purpose, documented approval and transparent payment channels.
×
No unofficial payment
Do not pay to accelerate routine action, obtain confidential information, influence an inspection or secure preferential treatment.
×
No gifts during active decisions
The safest approach during tenders, approvals, negotiations or inspections is no gift or hospitality to decision-makers.
✓
Escalate coercion or safety threats
Where a payment is demanded under threat to personal safety, prioritise safety, record what occurred and report immediately for review.
Third-Party Due Diligence
LDV Groove must know who acts on its behalf and how they are paid.
Risk-based diligence should occur before appointment and be refreshed when ownership, services, geography, government contact, payment arrangements or conduct changes.
01
Define the Need
Confirm why the intermediary is necessary, what services are expected and who approved the appointment.
02
Verify Identity
Check legal name, beneficial ownership, licences, address, bank account and connected persons.
03
Assess Red Flags
Review reputation, government ties, sanctions, conflicts, commissions, geography and prior allegations.
04
Contract & Approve
Set defined services, fees, anti-bribery commitments, records, audit rights and termination rights.
05
Monitor Performance
Confirm deliverables, invoices, payment route, ownership changes and emerging concerns throughout the relationship.
Never outsource accountability: LDV Groove may remain exposed when a distributor, consultant, customs broker, franchisee, sourcing agent or other representative pays a bribe for the Group’s benefit.
Gifts, Hospitality & Other Benefits
Courtesy must remain lawful, modest, transparent and unrelated to a decision.
Any permitted courtesy should have a legitimate business purpose, comply with the recipient’s rules, avoid cash or cash equivalents, receive required approval and be recorded accurately.
01
Permitted in Principle
Low-value, infrequent, transparent courtesy connected to a genuine business interaction and allowed by applicable rules.
- Lawful and proportionate
- No expectation of favourable treatment
- Documented recipient and purpose
02
Requires Review
Travel, hospitality, sponsorship, donations, repeated courtesies or anything involving public officials or active procurement.
- Prior written approval
- Recipient-policy check
- Enhanced documentation
03
Never Acceptable
Cash, gift cards, personal favours, secret benefits, lavish entertainment, benefits to relatives or anything linked to a decision.
- No concealment or split payments
- No active-tender influence
- No reimbursement through third parties
Financial Controls & Monitoring
Accurate books are a frontline anti-corruption control.
Every payment should reflect a genuine transaction, approved purpose, appropriate counterparty and complete supporting evidence. Vague descriptions and unsupported exceptions should trigger review.
01
Segregation of duties
Separate supplier creation, contracting, approval, payment release and reconciliation where practical.
02
Payment discipline
Use contracted legal entities and verified bank accounts; restrict cash, personal accounts and unexplained third-party payments.
03
Exception monitoring
Review round-sum invoices, unusual commissions, urgent overrides, duplicate payments, split transactions and high-risk descriptions.
04
Record integrity
Do not create false invoices, misleading expense categories, undisclosed funds or incomplete documentation.
Speaking Up, Investigation & Protection
Concerns should be raised early, handled confidentially and resolved without retaliation.
Employees and partners should be able to ask for guidance, refuse improper conduct and report suspected bribery, false records, retaliation or control bypasses through authorised channels.
01
Raise the Concern
Report suspected requests, payments, gifts, conflicts, false records or pressure to bypass approval.
02
Preserve Information
Keep relevant messages, invoices, contracts, approvals and other records; do not alter or destroy evidence.
03
Assess Independently
Use appropriately authorised reviewers, protect confidentiality and manage conflicts within the investigation team.
04
Remediate & Protect
Stop ongoing exposure, correct controls, apply proportionate consequences and protect good-faith reporters from retaliation.
Integrity Evidence Pack
Illustrative structure
01
Risk assessment
02
Due diligence & contracts
03
Approvals & payment records
04
Training, monitoring & response
Reporting & Assurance
Leaders need visibility over red flags, exceptions and corrective action.
Reporting should focus on material exposure rather than activity volume alone, including high-risk third parties, gifts and hospitality, payment exceptions, allegations, investigations and overdue remediation.
01
Risk and diligence status
Track higher-risk countries, sectors, intermediaries, public-official contact and unresolved red flags.
02
Approval and exception data
Review gifts, hospitality, donations, sponsorships, unusual commissions, cash activity and payment overrides.
03
Allegations and investigations
Escalate significant matters promptly while preserving confidentiality and legal privilege where applicable.
04
Remediation effectiveness
Verify root-cause actions, disciplinary outcomes, contract changes, training and control improvements to closure.
Related Governance Areas
Anti-corruption controls depend on connected governance, ethics and reporting mechanisms.
The related pages explain oversight, ethical standards, risk ownership and the wider compliance architecture supporting this framework.
Oversight
Board responsibilities, delegated authority and subsidiary accountability.
Controls
Obligation mapping, ownership, due diligence, monitoring and evidence.
Publication note: This page describes an intended anti-bribery and anti-corruption framework for LDV Groove Capital and its group companies. It does not confirm that a board-approved policy, gifts register, reporting channel, investigation protocol, training programme, quantified approval thresholds, certified management system or independent assurance plan is already adopted or operational. Final public content should be verified against current board approvals, employment terms, contracts, systems, local law and actual reporting arrangements.
Integrity in Every Market
Win business fairly. Record it truthfully. Stop improper influence.
Long-term value is protected when commercial success is separated from bribery, concealed benefits and unethical access.
Building businesses, creating brands and delivering long-term value through capital, strategy, partnerships and disciplined execution.
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