Business Ethics & Compliance
Last Updated: April 30, 2025
Our commitment to integrity, ethical conduct, and compliance with all applicable laws and regulations, including anti-corruption standards.
Our Commitment
Fari, Inc. ("Fari," "we," "us," or "our") is dedicated to conducting business with the highest standards of integrity, honesty, and fairness. We are committed to complying with all applicable laws and regulations in the jurisdictions where we operate, including those related to anti-corruption and ethical business practices. This Business Ethics & Compliance Policy outlines the principles and standards that guide our employees, officers, directors, and third-party partners.
As a provider of AI-driven software solutions for the hospitality industry, trust and transparency are paramount. This policy serves as a foundation for building and maintaining that trust with our clients, partners (including prospective partners like Oracle through the OPN program), and the broader community.
Code of Business Conduct
All Fari personnel are expected to:
- Act honestly, ethically, and with integrity in all business dealings.
- Comply fully with all applicable laws, rules, and regulations.
- Avoid conflicts of interest, both real and perceived.
- Maintain the confidentiality of proprietary information belonging to Fari, our clients, and partners.
- Treat colleagues, clients, partners, and competitors with respect and fairness.
- Protect Fari's assets and ensure their efficient use.
- Uphold Fari's commitment to data privacy and security as outlined in our Privacy Policy.
Anti-Corruption Policy
Fari strictly prohibits bribery and corruption in any form. This includes offering, promising, giving, requesting, or accepting anything of value, directly or indirectly, to or from any person (including private individuals and Government Officials) to improperly influence a decision, obtain or retain business, or secure an unfair advantage.
This prohibition applies globally and encompasses compliance with laws such as the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other applicable anti-corruption laws.
Key Prohibitions:
- Bribery: No Fari personnel or associated third party may offer or give bribes.
- Receipt of Bribes: No Fari personnel may solicit or accept bribes.
- Facilitation Payments: So-called "grease payments" or facilitation payments (small payments to expedite routine government actions) are generally prohibited. Any potential exceptions must be pre-approved by Fari's legal counsel.
- Indirect Corruption: We prohibit making payments to third parties if there is knowledge or suspicion that part of the payment will be used for corrupt purposes.
Gifts, Hospitality & Entertainment
Exchanging modest gifts, hospitality, and entertainment can be a legitimate way to build business relationships. However, such exchanges must never be intended to improperly influence, nor should they create the appearance of impropriety.
Guidelines:
- Permissibility: Must be reasonable, infrequent, transparent, permitted by local law and the recipient's organizational policies, and properly documented.
- Value: Must be of nominal or modest value. Lavish or excessive gifts or entertainment are prohibited.
- Nature: Must be appropriate for the business context and not involve cash or cash equivalents (except for very minor, customary exceptions like taxi fare reimbursement, subject to approval).
- Timing: Should not be offered or accepted during critical decision-making periods (e.g., contract negotiations).
- Transparency: All significant gifts, hospitality, or entertainment provided or received must be recorded accurately.
Specific, stricter rules apply when dealing with Government Officials (see next section).
Dealing with Government Officials
"Government Official" includes employees of government departments, agencies, state-owned enterprises, public international organizations, political parties, or candidates for office.
Interactions with Government Officials require heightened scrutiny due to strict anti-corruption laws. Providing anything of value, even modest hospitality, can be restricted or prohibited.
Requirements:
- Strict compliance with all applicable laws regarding interactions with Government Officials.
- Generally, providing gifts, meals, entertainment, or travel to Government Officials is prohibited without prior written approval from Fari's legal counsel.
- Any permitted hospitality must be directly related to the promotion, demonstration, or explanation of Fari's products or services, or the execution of a contract.
- Never provide anything of value in exchange for official action or inaction.
Commissions & Third Parties
Fari may engage third parties (agents, consultants, distributors, partners) to act on our behalf. We are responsible for ensuring these parties conduct business ethically and in compliance with this policy and applicable laws.
Requirements:
- Conduct appropriate due diligence before engaging third parties.
- Ensure agreements with third parties include anti-corruption compliance clauses.
- Commissions and fees paid must be reasonable and proportionate to the legitimate services rendered.
- Payments must be accurately documented and made through appropriate channels, generally to the third party's business entity in their country of operation.
- Never make payments knowing or suspecting they will be used for corrupt purposes.
Accurate Books & Records
Maintaining accurate and complete books, records, and accounts is crucial for transparency and compliance. All transactions, including expenses related to gifts, hospitality, and third-party payments, must be recorded accurately, timely, and in reasonable detail.
No undisclosed or unrecorded funds or assets are permitted. False, misleading, or artificial entries in Fari's books and records are strictly prohibited.
Reporting Concerns
Employees and partners have a responsibility to report any suspected violations of this policy or applicable laws. Reports can be made to:
- Your direct supervisor or manager.
- Fari's designated compliance officer or legal department via email at compliance@getfari.com.
Non-Retaliation: Fari strictly prohibits retaliation against anyone who, in good faith, reports a concern or participates in an investigation. We are committed to fostering an environment where concerns can be raised without fear of reprisal.
Training & Communication
Fari provides regular training to employees on this policy and relevant compliance topics. Key third-party partners may also receive training or be required to certify their compliance.
This policy is communicated to all employees and made available to relevant business partners.
Consequences of Violations
Violations of this policy or applicable anti-corruption laws can result in severe consequences for both Fari and the individuals involved, including significant fines, reputational damage, and criminal penalties.
Employees who violate this policy will be subject to disciplinary action, up to and including termination of employment, in accordance with local law. Violations by third parties may result in termination of the business relationship.
Policy Review & Updates
This Business Ethics & Compliance Policy is reviewed periodically and may be updated to reflect changes in laws, regulations, or Fari's business operations. The latest version will always be available on our website.
Questions regarding this policy should be directed to Fari's legal or compliance department at compliance@getfari.com.