Anti-Bribery Policy

Last Updated: 12 July 2026

Vietnam Direct Sourcing (“VDS”, “we”, “our”) connects importers with vetted manufacturers across Vietnam. Sourcing work regularly involves factory visits, customs processes, and third-party agents in markets where informal gifts and facilitation payments are common practice. This policy sets out how we handle that exposure so our clients’ procurement and compliance teams can engage with us with confidence.

1. Policy Statement

VDS has zero tolerance for bribery, kickbacks, and facilitation payments of any kind, by any person acting on our behalf, anywhere we operate. This applies to interactions with factories, freight forwarders, customs officials, inspection agencies, and government bodies, without exception.

2. Who This Applies To

This policy binds VDS’s founder, employees, contractors, sourcing agents, and any third party engaged to act on VDS’s behalf in Vietnam or any other jurisdiction.

3. Gifts & Hospitality

• Modest, occasional gifts and hospitality of clearly reasonable value are permitted where locally customary and directly connected to legitimate business (e.g., a factory tour lunch).
• No cash or cash-equivalent gifts (vouchers, gift cards) may be given or accepted, under any circumstances.
• Any gift or hospitality offered or received above a nominal value must be logged and disclosed to the founder before or immediately after the event.
• Gifts or payments intended to influence a business decision, inspection result, or contract award are prohibited outright, regardless of value.

4. Facilitation Payments

Facilitation payments — small, informal payments to speed up a routine government action (customs clearance, permit processing) — are prohibited, even where they are locally customary. If a legitimate service is delayed pending an improper payment, the issue is escalated to the founder rather than paid to resolve quietly.

5. Third Parties & Supplier Agreements

Sourcing agents, factories, and logistics partners engaged by VDS are expected to operate to the same standard. Anti-bribery expectations are written into supplier and agent agreements, and any credible report of a supplier offering improper payments to secure business results in review of that relationship.

6. Legal Framework

This policy is designed to keep VDS and its clients on the right side of the anti-bribery laws most relevant to our client base and operating footprint, including the US Foreign Corrupt Practices Act (FCPA), Australia’s foreign bribery provisions under the Criminal Code Act 1995 (Cth), the UK Bribery Act 2010, and Vietnam’s domestic anti-corruption law. It is not intended as legal advice; clients with jurisdiction-specific compliance requirements should confirm details with their own counsel.

7. Reporting a Concern

Anyone with a genuine concern about a bribe, gift, or facilitation payment connected to VDS’s work — staff, contractor, supplier, or client — can raise it directly and confidentially with the founder. Reports are taken seriously and investigated promptly; retaliation against anyone raising a concern in good faith is not tolerated.

8. Review

This policy is reviewed annually, or sooner if VDS’s entity structure, jurisdictions of operation, or client base change materially.

Questions about this policy: contact us via vietnam-directsourcing.com