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Company Ethics and Anit-corruption Policies

Lumentra Consulting Code of Ethics and Anti-Corruption Policy

 

Effective Date: 01-JAN-2025
Last Reviewed: 01-JUL-2025

 

Lumentra Consulting, LLC ("Lumentra") is committed to conducting its business with the highest standards of ethics, integrity, and transparency. This policy outlines our commitment to compliance with all applicable anti-corruption laws and ethical standards, including but not limited to:

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

  • The U.K. Bribery Act

  • Applicable local anti-bribery and corruption laws in countries where we operate

 

1. Anti-Corruption and Bribery
Lumentra strictly prohibits offering, promising, authorizing, giving, soliciting, or receiving anything of value—directly or indirectly—to or from any Government Official, customer, vendor, or business partner to improperly influence a business decision or secure an unfair advantage.

 

2. Gifts, Hospitality, and Entertainment
All gifts, hospitality, and entertainment must be:

  • Nominal in value (no more $10)

  • Infrequent

  • Transparent

  • Never intended to influence business decisions

Prior written approval from the Compliance Officer is required for any gift or hospitality involving Government Officials.

 

3. Business Ethics and Conduct
All employees and representatives of Lumentra are expected to:

  • Act with integrity in all business dealings

  • Avoid conflicts of interest

  • Comply with all applicable laws and company policies

  • Report any suspected violations promptly


4. Payment of Commissions and Third Parties
All payments to third-party agents, resellers, or consultants must:

  • Be transparent and properly documented

  • Reflect fair market value for legitimate services rendered

  • Be made only pursuant to a written agreement approved by legal/compliance


Lumentra conducts due diligence on all third-party representatives involved in government or customer interactions.

5. Training and Reporting
We provide anti-corruption and ethics training to all employees. Suspected violations can be reported confidentially to compliance@lumentra.ai or through our anonymous whistleblower portal.

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