POLICY
Anti-Bribery & Anti-Corruption Policy
Zero tolerance for bribery and corruption, anywhere we operate.
VERSION 2.0. EFFECTIVE 4 AUGUST 2026. NEXT REVIEW 4 AUGUST 2027.
SolarisTech Inc. is a Delaware corporation. The US Foreign Corrupt Practices Act is the baseline that applies to the company and to everyone acting on its behalf, wherever in the world the work is done. Where local law or a client's own standard is stricter, the stricter standard applies. We also work under the anti-bribery and anti-corruption laws of the countries where we operate, which currently include the United States, South Korea, Japan, Greece and India. Corruption is not only a legal exposure. Our work is bought because it is independent. A payment that buys a result destroys the product.
This policy applies to every director, employee, contractor and representative, and to third parties acting in our name.
Why this matters in our work
Our people deal routinely with individuals who are public officials for the purposes of the FCPA: flag administration staff, port State control officers, customs and immigration officers, port and terminal authorities, and employees of state-owned or state-controlled owners, yards and terminals. Employees of a classification society acting under a delegation from a flag State may also fall within that definition. Our standing instruction is to assume you are dealing with a public official unless it is clear that you are not.
What we prohibit
- Offering, giving, requesting or accepting a bribe, kickback or any improper payment or advantage, directly or through anyone else.
- Facilitation payments of any size, to anyone, in any country, including payments to speed up a routine clearance, attendance, inspection, stamp or certificate. Local custom is not a defense.
- Using charitable donations, sponsorships, political contributions, free training places or the offer of future work as a route to improper influence.
- Retaliating against anyone who refuses to pay a bribe or who reports one, including where the refusal costs us the job.
One narrow exception. If a person is confronted with an imminent threat to health, safety or liberty, they protect themselves first. Any payment made under that kind of duress must be reported to the President as soon as it is safe to do so, and it is recorded in our books for what it was.
Gifts and hospitality
Modest, occasional business courtesies are acceptable where they are transparent, proportionate and would not embarrass either side if they were published.
- Reasonable in value, infrequent, openly given and openly recorded.
- Never cash or a cash equivalent, including gift cards, vouchers, prepaid instruments or crypto assets.
- Never given or accepted while a tender, quotation, inspection, audit, appeal or dispute involving that party is live.
- Never given to or accepted from a public official without prior written approval from the President.
- Anything beyond a routine courtesy is declined, or escalated for approval before it is accepted.
Gifts and hospitality given or received above a nominal value are recorded in a register maintained by the President and are available to a client or lender conducting a reasonable review.
Third parties and due diligence
We engage third parties, and we act as a third party for others. Both directions are covered here. Where others act for us:
- We carry out proportionate due diligence on agents, intermediaries, sub-contractors and referral partners before appointing them, and we keep the record.
- Anti-bribery obligations, audit rights and a right to terminate for breach go into the written agreement.
- We pay a rate that matches the service actually delivered, to the contracted party, in the contracted country, against an invoice. No cash, no third-party accounts, no unexplained success fees.
- We do not appoint anyone we have reason to believe is likely to pay or accept a bribe on our behalf.
Where we act for others:
- SolarisTech maintains working relationships with classification societies. We perform them on the same terms we require of our own agents: written terms, accurate invoicing, and no payment of any kind to a public official in connection with the work.
- SolarisTech represents flag administrations internationally. That representation is performed on the same terms, and it confers no statutory authority on SolarisTech.
- Our remuneration under an agency or representation appointment is disclosed to a client in writing before any introduction, as set out in our Impartiality and Independence Policy.
- We do not accept an arrangement whose remuneration depends on a regulatory or certification outcome.
Books, records and the law
- We keep accurate and complete books and records. No undisclosed funds, off-book accounts, false invoices or misdescribed expenses.
- Every payment is recorded to reflect what it actually was.
- We comply with the US Foreign Corrupt Practices Act and with applicable anti-bribery and anti-corruption legislation in every country where we work.
- Where a contract provides for it, our engagement records are open to a client's or a lender's reasonable audit.
Anyone who suspects a breach of this policy must report it, to the President directly or in writing to admin@solaristechinc.com. A concern involving the President can be reported to the company's outside counsel, whose details we provide on request. Reports made in good faith are protected from retaliation, and we investigate them promptly and fairly. Breach may result in dismissal or termination of contract and referral to the authorities. Policy owner: Thomas H. Blenk, President and Chief Executive Officer. Reports and questions: admin@solaristechinc.com.
Other Policies
Questions About How We Work?
Ask for our certificates, our sub-processor list, our relationship and flag representation disclosures, or the scope of any engagement. We will send them.