Anti-Corruption Policy

Effective date: 15, September 2023

Trilliant Holdings Inc. and its Affiliates are committed to conducting business with the highest ethical standards and in compliance with applicable international laws against corrupt business practices.

Many nations have adopted some form of anti-corruption legislation, including the U.S. (the Foreign Corrupt Practices Act or FCPA), UK (Bribery Act), Colombia (Corruption of Foreign Public Officials Act), Malaysia (Malaysian Anti-Corruption Commission Act), India (Prevention of Corruption Act, 1988) and Singapore (Prevention of Corruption Act) (collectively, “Anti-Corruption Laws”).  These laws generally forbid bribing foreign officials for the purpose of obtaining or retaining business or influencing some other decision to benefit a business and extend in some jurisdictions to bribery whether or not a government official is involved.

Trilliant will not participate or condone bribery whether directed at government or private sector actors.    All Trilliant business partners must follow this policy as a condition of doing business with Trilliant.  All Trilliant officers, directors and employees must also adhere to these standards or face disciplinary action up to and including termination of employment.

Prohibited Conduct

Bribery is soliciting, offering or giving anything of value for the purpose of influencing a business decision.  It could be cash, gift cards, travel, lavish entertainment, or favors such as offering employment (even unpaid) to family members of the person to be influenced.  “Anything” of value must be understood literally:  it means anything.  Key here is the intention behind the offer.  If it is made to gain an advantage over others (often referred to as a “corrupt purpose”), it is probably bribery.  Further, this conduct is prohibited whether taken directly or indirectly, as through a 3d party intermediary.


To ensure compliance with the law, Trilliant has implemented a comprehensive, risk-based FCPA and anti-corruption due diligence work plan to address the use of agents and other third parties (e.g., resellers, sales agents, prime and sub-contractors), work with state-owned customers, teaming or consortium arrangements, among other arrangements.  The diligence investigation is conducted by Trilliant Legal Department, and includes a range of inquiries, depending on the circumstances, such as information requests to the potential business associate, background checks on companies and individuals, media and publicly available database reviews.

Business partners are also required to certify to compliance with Anti-Corruption Laws as well as all other applicable laws governing their business relationship with Trilliant.  Please also see Trilliant’s Supplier Code of Conduct.  For any questions about this policy, please contact the General Counsel at