Our commitment
We win and keep business on the quality of our work. We never offer, pay, request or accept a bribe, and we never allow anyone to do so on our behalf, regardless of local custom or business pressure.
This policy is approved by company leadership and reflects our commitment to honest, transparent business practices.
Who this policy applies to
This policy applies to all Radiant directors, officers, employees, contractors and temporary staff, and to agents, subcontractors, consultants, partners and other third parties who act for us or on our behalf (together, “associated persons”).
Laws we follow
We comply with all applicable anti-bribery and anti-corruption laws in every jurisdiction where we operate. These include the U.S. Foreign Corrupt Practices Act (FCPA), U.S. federal and state anti-bribery laws including those governing dealings with public officials, the federal Anti-Kickback Statute for healthcare-related work, and, where applicable, the UK Bribery Act 2010 and similar laws in other countries.
What is prohibited
Associated persons must never, directly or indirectly:
- Offer, promise, give or authorize anything of value to improperly influence a decision, win or keep business, or gain an unfair advantage
- Request, agree to receive or accept anything of value in return for improperly performing their role
- Offer or give anything of value to a government official, including employees of public hospitals, public agencies or state-owned companies, to influence an official act
- Offer or pay remuneration in exchange for healthcare referrals or business, in breach of anti-kickback laws
- Use a third party, family member, charity or other channel to do any of the above
“Anything of value” includes cash, cash equivalents, gifts, travel, entertainment, jobs or internships, loans, donations, discounts and favors.
Facilitation payments
We do not make facilitation payments, sometimes called “grease payments,” which are small unofficial payments to speed up routine government actions, even where local law may permit them. The only exception is a payment made under immediate threat to someone’s personal safety; any such payment must be reported to leadership as soon as possible and recorded accurately.
Gifts, hospitality and expenses
Modest, occasional gifts and hospitality can be a normal part of business relationships. They are acceptable only when they are:
- Reasonable in value and not given in cash or cash equivalents
- Given openly, not in secret, and not during a tender, bid or procurement decision involving the recipient
- Permitted under the recipient’s own organization’s rules
- Recorded accurately in our books
Any gift or hospitality involving a government official requires prior written approval from company leadership.
Political and charitable contributions
We do not make political contributions on the company’s behalf. Charitable donations and sponsorships must be approved in advance, made to legitimate organizations, and never used to disguise a bribe or influence a business decision.
Third parties
We carry out risk-based due diligence before engaging agents, subcontractors and partners who may interact with clients or officials on our behalf. Our contracts with these parties require compliance with anti-bribery laws and this policy, and we may end any relationship where we find a breach.
Accurate records
We keep complete and accurate books and records of all transactions, payments, gifts and expenses. No undisclosed or unrecorded accounts are permitted, and no record may be falsified or described in a misleading way.
Raising concerns
Anyone who suspects a breach of this policy, or who is asked to pay or accept a bribe, should report it promptly to company leadership or by email to contact@radiantcts.com. Concerns can be raised in confidence.
We do not tolerate retaliation against anyone who raises a concern in good faith or refuses to take part in bribery, even if refusing means we lose business.
Consequences of a breach
Breaching this policy may lead to disciplinary action up to and including termination of employment or contract. We will cooperate with the relevant authorities where required, and individuals may face personal criminal penalties under applicable law.
Training and review
All employees receive anti-bribery training when they join and at regular intervals afterward. Leadership reviews this policy at least once a year and updates it as laws and our business change.