ANTI-CORRUPTION POLICY
This Anti-Corruption Policy (“Policy”) sets forth the principles and rules governing the prevention of bribery and corruption in connection with the operations of Webisso LLC (“Company”, “we”, “us”, or “our”), including the GetTunnelVPN application.
1. Scope of Application
This Policy applies to all founders, officers, directors, employees, freelancers, contractors, consultants, agents, representatives, and any third parties acting on behalf of Webisso LLC, regardless of location or duration of engagement.
Compliance with this Policy is mandatory for all covered parties. Any violation shall be considered a serious breach.
2. Zero-Tolerance Approach
Webisso LLC adopts a strict zero-tolerance policy toward bribery and corruption. Any form of bribery, kickback, improper payment, or corrupt practice is strictly prohibited.
3. Prohibition of Bribery
No covered person may directly or indirectly offer, promise, authorize, give, request, or accept any bribe, improper payment, or anything of value for the purpose of influencing any business decision or securing an improper advantage.
This prohibition applies to dealings with both private parties and government officials.
4. Government Officials
Webisso LLC does not currently conduct direct business with government entities. If such interactions occur in the future, they shall be subject to strict compliance with this Policy and all applicable anti-corruption laws.
Any payments, gifts, benefits, or advantages provided to government officials are strictly prohibited.
5. Facilitation Payments
Facilitation payments, including small or unofficial payments intended to expedite routine governmental actions, are strictly prohibited under all circumstances.
6. Third Parties and Intermediaries
The Company may engage third parties, including but not limited to affiliate or referral partners, influencers, advertising partners, and global server or infrastructure providers.
All third-party relationships must be based on legitimate business purposes, written agreements, and transparent commercial terms.
Revenue-sharing or performance-based arrangements may be used only where contractually documented, commercially reasonable, and compliant with this Policy.
Webisso LLC shall not use third parties to circumvent anti-corruption obligations. Any corrupt conduct by a third party acting on behalf of the Company will be treated as a violation of this Policy.
7. Payments and Financial Controls
All payments made by or on behalf of the Company must be:
- Conducted through authorized platforms or payment processors, including mobile platforms or Stripe
- Fully documented
- Supported by valid invoices or contractual documentation
Cash payments and undocumented or off-the-books transactions are strictly prohibited.
8. Gifts, Hospitality, and Entertainment
Only reasonable, nominal, and promotional gifts are permitted. Gifts or hospitality intended to influence business decisions, secure improper advantages, or provided to government officials are strictly prohibited.
Cash gifts, gift cards, travel expenses, luxury entertainment, or excessive hospitality are not permitted under any circumstances.
9. Compliance with Laws
This Policy is intended to ensure compliance with all applicable anti-corruption laws and regulations, including but not limited to:
- The U.S. Foreign Corrupt Practices Act (FCPA)
- The UK Bribery Act
- Applicable local and international anti-corruption laws
10. Reporting Violations
Any suspected or actual violation of this Policy must be reported immediately by contacting the Company at:
Email: [email protected]
Reports may be made in good faith. Failure to report known violations may itself constitute a breach of this Policy.
11. Enforcement and Disciplinary Action
Violations of this Policy may result in severe disciplinary action, including but not limited to:
- Immediate termination of employment or engagement
- Termination of contractual relationships
- Reporting to relevant legal or regulatory authorities
The Company reserves the right to pursue all available legal remedies.
12. Training and Monitoring
The Company does not currently operate a formal anti-corruption training program. However, training, monitoring, or internal controls may be implemented at the Company’s discretion in the future.
13. Binding Effect
This Policy is binding on all covered persons and applies to all business relationships. Non-compliance shall be treated as a material violation.
14. Governing Law
This Policy shall be governed by and construed in accordance with the laws of the State of Wyoming, United States.
15. Policy Updates
Webisso LLC reserves the right to amend or update this Policy at any time. Continued association with the Company constitutes acceptance of the updated Policy.