Kuber Ventures Limited values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:
Kuber Ventures Limited prohibits:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement
to or from any person or company, wherever they are situated and whether they are a public official or body orprivate person or company
by
any individual consultant, agent or other person or body acting on the Company’s behalf
in order to
gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical
or in order to
gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual
The Company recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Partnership or of the person or body employing or contracting with them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer
The prevention, detection and reporting of bribery is the responsibility of all consultants throughout the partnership. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.
Useful resource: www.transparency.org.uk for the Transparency Index
A fuller Policy and Procedures outlining all the Principals of the Act can be requested
From the Compliance Officer of the Partnership by emailing info@kuberventures.com
An investor qualifies as an High Net Worth investor if they have
(a) An annual income to the value of £100,000 or more;
(b) Net assets to the value of £250,000 or more. Net assets for these purposes do not include:
(i) the property which is their primary residence or any loan secured on that residence;
(ii) any rights under a qualifying contract of insurance within the meaning of the Financial
Services and Markets Act 2000 (Regulated Activities) Order 2001; or
(iii) any benefits (in the form of pensions or otherwise) which are payable on the termination of their service or death or retirement and to which they are or (or their dependants are), or may be, entitled.
An investor qualifies as ar Self-Certified Sophisticated Investor if at least one of the following applies:
a) they are a member of a network or syndicate of business angels and have been so for at least the last six months prior to the date below
b) they have made more than one investment in an unlisted company in the two years prior to the date below
c) they are working, or have worked in the two years prior to the date below, in a professional capacity in the private equity sector, or in the provision of finance for small and medium sized enterprises
d) they are currently, or have been in the two years prior to the date, below a director of a company with an annual turnover of at least £1 million