Anti-Bribery and Corruption Policy

Version 2.0. Effective 31 July 2026. Next review 31 July 2027.

1. Purpose and scope

Auren Institute prohibits bribery and corruption in every form, in every country in which we operate, without exception and regardless of local practice.

Auren Institute is registered in Malta at 92, No. 1, St Edward Street, Qormi QRM 2136, Malta, registration P1421, VAT MT20967027. We operate in Malta and the United Kingdom, so this policy addresses the law of both.

This policy applies to everyone acting for us, including associate trainers, resellers, affiliates and introducers.

2. The law we work to

• United Kingdom: Bribery Act 2010. Section 1 bribing another person, section 2 being bribed, section 6 bribery of a foreign public official, and section 7 failure of a commercial organisation to prevent bribery.
• Malta: Criminal Code, Chapter 9 of the Laws of Malta, in particular the provisions on bribery and trading in influence.
• Malta: Permanent Commission Against Corruption Act, Chapter 326 of the Laws of Malta.

Section 7 of the Bribery Act 2010 makes an organisation liable where a person associated with it bribes on its behalf. The only defence is having adequate procedures in place. This policy, the training behind it, and the records described below are those procedures.

3. What is prohibited

• Offering, giving, requesting or accepting any financial or other advantage intended to induce or reward improper performance.
• Facilitation payments, meaning small unofficial payments to speed up a routine action. These are bribes and are prohibited, including where local practice tolerates them.
• Kickbacks of any kind, including undisclosed payments to individuals who influence a purchasing decision.
• Political donations made in the name of Auren Institute.
• Charitable donations used as a route to secure business.

4. Gifts and hospitality

Modest, occasional and transparent hospitality is acceptable. Anything intended or likely to influence a decision is not.

A gifts and hospitality register is maintained by the Managing Director and reviewed annually. The thresholds above are our own policy, not a legal safe harbour: a gift below a threshold is still a bribe if it is intended to influence.

5. Third parties

Anyone acting for us is bound by this policy. Before appointing a reseller, affiliate, introducer or agent we establish who owns and controls them, and the agreement records their obligation to comply. We terminate arrangements where this policy is breached.

6. Reporting

Report any concern to the Managing Director at info@aureninstitute.com. If the concern involves the Managing Director, report it to our external accountants or legal advisers, whose details are available on request.

Reports may be made in confidence. No one who raises a concern in good faith will suffer any detriment, and we treat retaliation as a disciplinary matter in its own right. This applies whether or not the concern is upheld.

7. Records and training

We keep the gifts and hospitality register, third party due diligence records, and any report made under this policy for six years. Everyone acting for Auren Institute completes anti-bribery training on joining and at least every two years afterwards.

Ownership and review

This policy is owned by the Managing Director of Auren Institute and applies to all directors, employees, contractors, associate trainers and anyone acting for Auren Institute.

It is reviewed annually, and sooner if the law changes, if an incident occurs, or if our operations change materially. The version and effective date are shown at the top of this page.

Questions about this policy, and any report made under it, go to info@aureninstitute.com, marked for the attention of the Managing Director.