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Anti-Bribery & Corruption Policy

1. Introduction & purpose

Trustpilot Group plc and its group companies (together referred to as "Trustpilot", "we", "our" or “us”) are committed to doing business in an honest and ethical manner.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity and transparency in all our business dealings and relationships wherever we operate in the world.

Bribery and corruption can expose Trustpilot, the people who work for us, and those we do business with, to severe civil and criminal liability, investigations, fines and penalties - as well as undermine our reputation and vision to be a universal symbol of trust.

Our position is clear: We do not engage in corruption and we don’t pay bribes, regardless of local custom or practice. The offer, payment, authorisation, solicitation and acceptance of bribes is unacceptable.

This Anti-Bribery & Corruption Policy (the "Policy") requires compliance with all applicable laws and regulations on bribery and corruption, including without limitation the UK Bribery Act 2010, the Danish Criminal Code, the U.S. Foreign Corrupt Practices Act, the Australian Criminal Code 1995 (Cth), the Australian Corporations Act 2001 (Cth) and relevant state and territory legislation in Australia.

The purpose of this Policy is to set out and explain the prohibitions against bribery and corruption in Trustpilot’s business practices, and reinforce our commitment to carrying out business globally with honesty and integrity.

2. Who is covered by this policy?

This policy applies globally to everyone who works for or on behalf of Trustpilot in any capacity, wherever they are located, including employees, officers, directors, workers, agents, contractors, consultants, representatives and business partners (together referred to as "you" or "your").

We also expect the people we do business with, including our customers and suppliers, to operate lawfully, ethically and with integrity, and share our commitment to responsible business practices.

3. Definitions

Bribery

Anything of value that is offered, provided, authorised, requested or accepted in order to improperly influence a person’s actions or decisions for the purposes of gaining or retaining an advantage.

A bribe may be monetary or non-monetary, tangible or intangible. A bribe may take the form of, or be facilitated through:

  • payments of money

  • gifts and entertainment

  • kickbacks and favours

  • discounts and favourable contract terms

  • promises of a business opportunity

  • donations, contributions and sponsorships

  • use of property or assets at a discount or free of charge

  • overpayments to business partners

  • information or assistance

Corruption

The misuse of power or position for personal gain.

Entertainment

Any activity received for free or less than market price, such as meals, travel, accommodation, sporting events, recreational activities and other hospitality.

Facilitation payment

Also known as ‘grease’ payments, facilitation payments are typically small, unofficial payments made to public officials to speed up or secure the performance of routine governmental duties or actions that should ordinarily be carried out without having to make such payments — for example:

  • Issuing permits or licences

  • Processing visas or other official documents

  • Clearing goods through customs or handling cargo

Gifts

Any items of value or benefits given at no cost to the recipient.

Kickbacks

A type of unofficial commission for preferential treatment or improper services received.

Public official

  • any officer, employee or representative of a state or a state-controlled or state-owned enterprise or entity;

  • any officer, employee or representative of any local, state, regional or national government institution, department, agency or ministry;

  • any person holding a legislative, administrative, judicial position or public function of any kind; and

  • any officer or representative of a political party, or any candidate for a political office.

4. Key prohibitions

  • You must not offer, give or authorise bribes of any kind, including facilitation payments, to any person in order to improperly influence their actions or decisions in order to gain or retain an advantage.

  • You must not request or accept bribes of any kind in order to obtain or maintain an improper advantage for someone else.

These prohibitions apply regardless of whether:

  • the bribe is made to or from a public official or private individual;

  • the bribe is made directly, or indirectly through a third party; and