Anti-Bribery Policy
Sugary has zero tolerance for bribery and corruption. This policy sets out what we expect from our team, our partners and everyone who sends gifts through Sugary.
Last updated
The short version
A quick guide to what matters most. The full text below is what applies.
- Zero toleranceWe never offer, pay, request or accept a bribe, in any form, anywhere we operate.Section 1
- It applies to everyoneOur team, our Stores and partners, and anyone who uses Sugary to send gifts.Section 2
- Gifts are fine, influence isn’tA gift should say thank you, not buy a decision. Intention, value and timing all matter.Section 4
- Extra care with officialsGifts to public officials are restricted almost everywhere. Check the rules before you send one.Section 5
- No “speed money”We don’t make facilitation payments, however small and however common they are locally.Section 6
- Speak up safelyReport concerns in confidence. We don’t tolerate retaliation against anyone who raises one in good faith.Section 12
Our commitment
Sugary has zero tolerance for bribery and corruption. We never offer, promise, give, request or accept a bribe, directly or through anyone else, to win or keep business or to gain any improper advantage.
We follow the anti-bribery laws of every country where we operate. Depending on where and how we act, these include the UAE Penal Code, Bangladesh’s anti-corruption laws, the US Foreign Corrupt Practices Act and the UK Bribery Act. Where this policy is stricter than local law, this policy applies.
Who this policy applies to
- Everyone who works for or on behalf of Sugary, including employees, contractors and agents.
- Stores, delivery partners, suppliers and other partners, whenever they act in connection with Sugary.
- Anyone who uses Sugary to send gifts, including businesses using Sugary for corporate gifting.
What counts as a bribe
A bribe is anything of value offered, promised, given, requested or accepted to improperly influence how someone does their job, or to reward them for doing it improperly.
It doesn’t have to be cash. Gifts, gift cards, hospitality, travel, discounts, jobs, donations and favours can all be bribes, including when they go to someone’s family or friends.
An offer is enough. A bribe doesn’t have to be accepted, or to work, to break the law.
Gifts and hospitality
Gifts and hospitality are a normal way to say thank you, and helping people do that well is what Sugary is for. A gift is acceptable when it’s given openly, is reasonable in value and isn’t meant to influence a decision. Three questions help:
- Intention
- Is it to say thank you or mark an occasion, or to win favour or a decision? Only the first is acceptable.
- Value
- Is it modest and in proportion to the relationship and the occasion? Lavish or frequent gifts deserve a closer look.
- Timing
- Is a decision pending, such as a tender, contract renewal or approval? The same gift can look very different at that moment.
A gift is never acceptable if it’s:
- cash, or anything that works like cash, given to influence a decision
- linked to a request, decision or favour
- something the recipient isn’t allowed to accept under the law or their employer’s rules
- hidden from the recipient’s employer, or recorded inaccurately
Our own team gives and accepts gifts and hospitality only within our internal guidelines, and records them where those guidelines require.
Public officials
Public officials include government employees, people working for state-owned or state-controlled companies, and officials of public international organisations. Gifts to them are tightly restricted in most countries, and banned outright in some.
Before sending a gift to a public official, check the rules that apply to them. Never send one while they’re considering a matter that affects you or your business.
Facilitation payments
Facilitation payments are small unofficial payments to speed up a routine action, such as issuing a permit or clearing goods. We don’t make them, even where they’re common.
The only exception is a payment demanded under threat to someone’s personal safety. If that happens, put safety first, then tell us as soon as you can.
Charitable and political contributions
We don’t make political contributions. Charitable donations and sponsorships must be legitimate and transparent, and never made to gain a business advantage.
Stores and other partners
We expect Stores, delivery partners and suppliers to follow anti-bribery laws and this policy whenever they work with us. We may check partners before and during our relationship, and we may end a relationship that breaches this policy.
Nobody may pay a bribe on Sugary’s behalf, and we won’t use a partner to do anything we wouldn’t do ourselves.
Using Sugary to send gifts
Sugary must never be used to bribe anyone. We may refuse or cancel an order we reasonably believe is intended as a bribe, suspend the account involved, and report it where the law requires, as our Terms of Use allow.
If you send gifts for a business, it’s your responsibility to follow your own organisation’s rules and the recipient’s. Many organisations limit what their staff can accept.
Gifting laws by country
Rules on gifts to public officials vary widely between countries. The guide below is a general overview, not legal advice, and laws change, so check the current rules or take advice before relying on it.
United Arab Emirates (UAE)
Penal Code (Decree-Law No. 31/2021) & HR Law No. 49/2023
Public officials are strictly prohibited from soliciting or accepting gifts or hospitality that could influence official duties or create a conflict of interest; federal employees may generally only accept promotional items of nominal value as permitted by institutional regulations.
Australia
Asia-PacificCriminal Code Act 1995 (Cth, Section 141.1)
Offering or providing any benefit to a Commonwealth public official with the intention of influencing their duties is a criminal offence; public officials must generally refuse gifts that could give rise to a real or apparent conflict of interest.
Bangladesh
Asia-PacificPenal Code 1860 & Conduct Rules 1979
Public servants are barred from accepting gifts without government sanction, except customary gifts of trifling value (foreign-government gifts up to Tk 500 / ~USD 4.50 may be retained without surrender).
Brazil
AmericasClean Company Act (Law No. 12,846/2013)
Promising, offering, or giving any undue advantage to a public official is strictly prohibited; the Federal Public Official Code of Conduct (Decree No. 4,081/2001) establishes a de minimis ceiling of 100 BRL (~USD 18) for institutional gifts.
Cambodia
Asia-PacificAnti-Corruption Law (2010, Art. 57–58)
Offering or giving any gift, favor, or advantage to a public official to perform or refrain from their duties constitutes criminal bribery; no statutory de minimis exception exists.
Canada
AmericasCriminal Code (s. 121) & Conflict of Interest Act
Public office holders are prohibited from accepting any gift or advantage that might reasonably be seen to have been given to influence them; gifts exceeding 200 CAD (~USD 145) must be publicly declared.
China
Asia-PacificCriminal Law (Art. 389–390) & AUCL
Offering money or property to state functionaries is a criminal offence; administrative regulations prohibit officials from accepting gifts that could affect impartial official duties, with gifts exceeding 200 RMB (~USD 28) generally deemed inappropriate.
France
EuropeSapin II Law (No. 2016-1691) & Penal Code
Offering any advantage to a public official to act or refrain from acting is corruption; customary business gifts are scrutinized under strict ethical rules and typically should not exceed 150 EUR (~USD 160) per calendar year.
Germany
EuropeGerman Criminal Code (StGB §§ 331–334)
Federal officials are forbidden from accepting gifts, rewards, or favors in relation to official duties without prior official consent; customary promotional items are generally restricted to a de minimis value of 25 EUR (~USD 27).
Hong Kong
Asia-PacificPrevention of Bribery Ordinance (POBO, Cap. 201)
It is an offence to offer an advantage to a public servant without lawful authority; public servants cannot solicit or accept gifts without explicit permission from the Chief Executive.
India
Asia-PacificPrevention of Corruption Act, 1988 (2018 adv.)
Public servants are prohibited from accepting lavish hospitality or gifts from parties with official dealings; gifts on traditional occasions must not exceed 5,000 INR (~USD 60) for Group A/B officers without formal report.
Indonesia
Asia-PacificAnti-Corruption Law (No. 31/1999 & No. 20/2001)
Any gratification given to a civil servant or state official is presumed a bribe if related to their position; recipients must report any gratification to the Corruption Eradication Commission (KPK) within 30 working days to avoid criminal penalties.
Japan
Asia-PacificNational Public Service Ethics Act (1999)
Bribing a public official is illegal; officials at the rank of Assistant Director and above must disclose any gift, hospitality, or remuneration exceeding 5,000 JPY (~USD 35).
Malaysia
Asia-PacificMACC Act 2009 (Section 17A)
Giving or receiving any gratification to influence official acts is an offence; public officers must refuse gifts unless difficult to decline, in which case formal departmental approval is required.
Mexico
AmericasFederal Penal Code (Art. 222) & GLAR (Art. 52)
Public officials are strictly prohibited from soliciting, demanding, or receiving gifts, favors, or services from persons or entities whose commercial activities they regulate or supervise.
Myanmar
Asia-PacificAnti-Corruption Law (2013) & Guideline 1/2016
Public officials are prohibited from accepting gifts; customary gifts up to 25,000 MMK (~USD 12) may be accepted from friends or relatives, but gifts from entities with business ties are strictly forbidden.
New Zealand
Asia-PacificCrimes Act 1961 (s. 99–105) & PSC Standards
Bribing an official is a serious offence; public servants must not accept gifts or hospitality that could compromise their integrity, create an obligation, or exceed nominal agency disclosure thresholds.
Nigeria
AfricaICPC Act 2000 & 5th Schedule of Constitution
Public officers are prohibited from accepting gifts or benefits on account of anything done in the discharge of official duties; only customary gifts of nominal value from personal friends are exempted.
Philippines
Asia-PacificRA 3019 (Anti-Graft) & RA 6713 (Code of Conduct)
Giving or receiving gifts tied to a public officer's duties during any occasion is punishable; only unsolicited gifts of nominal value not given in anticipation of favor are excepted.
Qatar
Middle EastPenal Code (Law No. 11 of 2004, Art. 140–147)
Offering or giving any benefit to a public official to act or refrain from acting in their official capacity is a felony; public officials are barred from accepting gifts that could influence their duties.
Saudi Arabia
Middle EastAnti-Bribery Law (Royal Decree M/36 of 1992)
Public servants are strictly prohibited from soliciting or accepting any gifts, gratuities, or favors in connection with official duties; offering any benefit to influence an official act carries severe criminal penalties.
Singapore
Asia-PacificPrevention of Corruption Act (PCA, Cap. 241)
Giving or receiving any gratification as an inducement is illegal; civil servants cannot retain gifts unless formally declared and approved by a Permanent Secretary, and gifts kept personally must not exceed SGD 50 (~USD 37).
South Africa
AfricaPRECCA (Act 12 of 2004)
Offering or accepting any gratification to influence an official act is a criminal offence; public service regulations require officials to disclose all gifts and hospitality exceeding 350 ZAR (~USD 20).
South Korea
Asia-PacificImproper Solicitation & Graft Act (2016)
Public officials cannot accept gifts over strict statutory limits: generally 50,000 KRW (~USD 36) for gifts and 150,000 KRW (~USD 108) for agricultural/livestock gifts, even without direct relation to duties.
Switzerland
EuropeSwiss Criminal Code (Art. 322ter–322decies)
Federal employees are prohibited from accepting gifts or advantages in connection with their official activities; social gifts of minor value up to 200 CHF (~USD 225) are permitted only if they do not compromise independence.
Thailand
Asia-PacificOrganic Act on Anti-Corruption (B.E. 2561)
Government officials are prohibited from accepting gifts or benefits valued over 3,000 THB (~USD 85) from anyone other than family members on ethical or customary occasions.
United Kingdom
EuropeBribery Act 2010 (Sections 1, 2, and 6)
Corporate hospitality and gifts must be reasonable, proportionate, and transparent; offering gifts or hospitality with the intention of inducing improper conduct or influencing a foreign public official is a criminal offence.
United States
AmericasFCPA (15 U.S.C. § 78dd-1) & 18 U.S.C. § 201
Offering anything of value to influence an official act is illegal; federal executive branch employees are subject to the $20 / $50 rule (gifts under USD 20 per occasion, up to USD 50 annually per source).
Vietnam
Asia-PacificPenal Code (Art. 354 & 364) & Anti-Corruption Law
Public officials are prohibited from accepting gifts in any form from agencies or individuals related to their duties; offering any benefit valued at 2,000,000 VND (~USD 80) or above constitutes criminal bribery.
Accurate records
We keep accurate books and records of payments, gifts and hospitality, and never disguise or misdescribe a payment.
Speaking up
If you’re asked for a bribe, suspect one, or think you may have broken this policy by mistake, tell us as soon as possible. We handle every report confidentially and will work with you to put things right.
We won’t tolerate retaliation against anyone who raises a concern in good faith, even if it turns out to be mistaken.
Breaches
Breaching this policy may lead to disciplinary action up to dismissal, the end of a business relationship, closure of an account, and reporting to the authorities. Bribery is a crime, and individuals as well as companies can face fines and imprisonment.
We review this policy regularly and may update it. The date at the top shows when it last changed.
Need to raise a concern?
Tell us what happened. Every report is handled confidentially.