Posted: January 1, 2026
Effective: January 1, 2026 – December 31, 2026
Entities Covered: Digify Pte Ltd (Singapore) and Digify Inc. (United States)
You can see previous policy here.
1. Introduction
Digify maintains a zero-tolerance approach to bribery and corruption. We are committed to conducting business honestly, transparently, and in full compliance with applicable anti-corruption laws, including:
This policy applies to Digify Pte Ltd (Singapore), Digify Inc. (United States), and all affiliated operations.
2. Scope
This policy applies to:
All individuals covered by this policy are expected to comply with its provisions at all times.
3. Definitions
For the purposes of this policy:
Bribery means offering, promising, giving, requesting, or accepting any financial or other advantage to improperly influence a decision or secure an improper business advantage.
Public Official includes any officer or employee of a government, government department, agency, state-owned enterprise, public international organisation, or any person acting in an official capacity.
Facilitation Payments are unofficial payments made to secure or expedite routine governmental actions.
Improper Advantage means any benefit obtained through unlawful or unethical means.
4. Prohibited Conduct
Digify strictly prohibits:
Facilitation payments are prohibited regardless of local custom or practice, except in circumstances involving an immediate threat to health or safety. Any such incident must be reported promptly.
Bribery of public officials and private individuals is equally prohibited.
5. Gifts, Hospitality, and Business Courtesies
Gifts, hospitality, or business courtesies must:
Gifts or hospitality involving public officials require prior approval from senior management.
Where internal thresholds apply, gifts and hospitality exceeding those thresholds must be approved in advance in accordance with company procedures.
Cash gifts or cash equivalents are strictly prohibited.
6. Conflicts of Interest
Employees and contractors must avoid situations where personal interests conflict, or appear to conflict, with Digify’s interests.
Any actual or potential conflict of interest that could give rise to bribery or corruption risk must be disclosed promptly to management.
7. Third-Party Relationships
Digify seeks to engage reputable third parties who share our commitment to ethical business conduct.
Third-party engagements may be subject to risk-based review appropriate to the nature of the relationship. Where appropriate, contracts may include anti-corruption representations and compliance obligations.
Digify does not permit third parties to engage in bribery or corruption on its behalf.
8. Books, Records, and Financial Integrity
All financial transactions must be accurately and fairly recorded in Digify’s books and records in reasonable detail and supported by appropriate documentation.
False, misleading, incomplete, or undisclosed records are strictly prohibited.
No undisclosed or unrecorded funds or accounts may be maintained for any purpose.
9. Reporting and Whistleblowing
Any individual covered by this policy who becomes aware of suspected bribery or corruption must report it promptly through:
Reports may be made confidentially in accordance with the Whistleblower Policy.
Digify prohibits retaliation against any individual who raises concerns in good faith. –
10. Training and Awareness
Digify promotes awareness of anti-bribery and corruption requirements through onboarding processes and periodic guidance appropriate to role and risk exposure.
Employees and contractors are expected to familiarise themselves with this policy and comply with its requirements.
11. Governance and Oversight
The CEO and senior management are responsible for fostering a culture of integrity and ensuring appropriate measures are in place to prevent bribery and corruption.
Day-to-day oversight of this policy is assigned to designated management personnel.
12. Policy Review
This policy is reviewed at least annually and may be updated to reflect changes in applicable law, regulatory expectations, or operational risk.
Augustine Lim
CEO
Digify Pte Ltd
Digify Inc.
30th December 2025