Anti-Corruption Policy

Basnet Attorneys & Law – A Premier Law Firm in Bhutan 

Effective Date: February 2, 2025

1. Introduction

Basnet Attorneys & Law upholds the highest standards of integrity, professionalism, and ethical conduct. This Anti-Corruption Policy sets out the Firm’s zero-tolerance position toward bribery, corruption, and improper influence in all professional and business activities. The Firm is committed to conducting its affairs in a manner consistent with the Anti-Corruption Act of Bhutan and internationally recognized principles of transparency and accountability.

2. Purpose

The purpose of this Policy is to establish a clear framework that prevents, detects, and responds to corruption in all forms. It aims to safeguard the Firm, its clients, and its partners from unethical practices and to ensure that all decisions made within the Firm reflect independent professional judgment and lawful conduct.

3. Scope

This Policy applies to all partners, lawyers, employees, trainees, interns, consultants, and contractors engaged by the Firm. It also extends to any individual or entity acting on behalf of the Firm, both within Bhutan and internationally. All persons covered by this Policy are expected to familiarise themselves with its provisions and comply fully with its requirements.

4. Firm Position on Corruption

Basnet Attorneys & Law strictly prohibits the offering, giving, soliciting, or receiving of any bribe, kickback, facilitation payment, or benefit intended to improperly influence any decision or secure an unfair advantage. The Firm does not permit any act that may be perceived as corrupt or that undermines the independence of legal judgment. Ordinary hospitality and customary courtesies may be exchanged only when they are modest, lawful, appropriate, and incapable of influencing professional decisions.

5. Financial and Record Integrity

All financial records, billing practices, and accounting documentation must reflect transactions accurately and transparently. False entries, undisclosed accounts, and off-the-record transactions are strictly forbidden. The Firm maintains internal controls to ensure proper documentation, oversight, and compliance with ethical and regulatory requirements.

6. Responsibilities of Personnel

All individuals covered by this Policy have a duty to uphold the Firm’s standards and avoid conduct that could be interpreted as corrupt. Personnel must act with honesty, avoid conflicts of interest, and maintain independence in the discharge of their professional duties. When faced with ethical uncertainty, individuals are expected to seek guidance from the Managing Partner or designated Compliance Officer.

7. Reporting Concerns

Any employee, partner, or third party who becomes aware of conduct that may violate this Policy must report the matter immediately. Reports may be made directly to the Managing Partner or through any internal reporting mechanism established by the Firm. The Firm ensures that all reports are handled confidentially and investigated promptly and thoroughly.

8. Non-Retaliation Statement

The Firm prohibits retaliation against any person who reports suspected misconduct in good faith. Individuals acting honestly and responsibly when raising concerns will be protected, regardless of the outcome of the investigation.

9. Consequences of Violations

Violations of this Policy may result in disciplinary action, including termination of employment or engagement. Where appropriate, the Firm may also report misconduct to competent authorities, including the Anti-Corruption Commission of Bhutan, and cooperate fully in any ensuing investigation. Individuals may also be subject to civil or criminal liability under Bhutanese law.

10. Review and Amendments

This Policy is reviewed periodically to ensure that it remains aligned with legislative developments, regulatory expectations, and evolving international best practices. The Firm reserves the right to amend or expand this Policy as necessary to maintain the highest standard of integrity in all aspects of its operation.