Anti-Corruption and Business Ethics Policy

1. Purpose

This policy establishes guidelines to ensure compliance with anti-corruption laws and to promote ethical business conduct within the organization. The aim is to prevent bribery, corruption, and unethical practices in all business dealings.

2. Scope

This policy applies to all employees, officers, directors, and agents of the organization, including third parties acting on behalf of the organization, such as consultants, contractors, and suppliers.

3. Anti-Corruption Compliance

• Prohibition of Bribery: The organization strictly prohibits offering, giving, receiving, or soliciting any form of bribe or improper payment to or from any individual, government official, or entity, whether directly or indirectly, to obtain or retain business, secure an improper advantage, or influence any act or decision.
• Facilitation Payments: Facilitation payments, even if small in amount, are prohibited unless there is a reasonable concern for personal safety. In such cases, the payment must be reported immediately to the Compliance Officer.
• Due Diligence: Proper due diligence must be conducted before engaging with third parties to ensure they comply with anti-corruption laws and ethical standards. Contracts with third parties should include anti-corruption clauses.

4. Gifts and Entertainment

• Gifts to Government Officials: Offering or giving gifts, hospitality, or entertainment to government officials is prohibited, except for nominal, customary gifts as permitted by local laws and approved by the Compliance Officer.
• Gifts to Non-Government Officials: Reasonable and customary gifts and entertainment may be provided to customers and business partners, provided they are not intended to influence business decisions and do not violate any laws or the recipient's policies. All gifts and entertainment must be reported to and approved by the Compliance Officer.
• Acceptance of Gifts: Employees must not accept gifts, hospitality, or entertainment that could create a conflict of interest or appear to influence business decisions. Any such offers must be reported to the Compliance Officer.

5. Payment of Commissions and Fees

• Legitimate Payments Only: Commissions, fees, and other payments to agents, consultants, or intermediaries must be for legitimate services and at market rates. Such payments must be documented clearly and transparently.
• Approval Process: All commission and fee arrangements must be reviewed and approved by the Finance Department and the Compliance Officer. Payments must be made in accordance with the organization's financial procedures.
• No Unrecorded Payments: The organization prohibits the making of any unrecorded or improperly documented payments. All payments must be accurately recorded in the company's financial records.

6. Training and Awareness

• Regular Training: Employees will receive regular training on anti-corruption laws, business ethics, and this policy. New employees will receive training as part of their onboarding process.
• Certification: All employees must certify annually that they have read, understood, and will comply with this policy.

7. Reporting and Whistleblowing

• Reporting Concerns: Employees are encouraged to report any concerns or suspicions of bribery, corruption, or unethical behavior. Reports can be made anonymously through the company’s whistleblowing hotline or directly to the Compliance Officer.
• Protection for Whistleblowers: The organization is committed to protecting employees who report concerns in good faith from retaliation or any form of adverse treatment.

8. Disciplinary Action

• Violations: Any employee found to have violated this policy will be subject to disciplinary action, which may include termination of employment and legal action.
• Third Parties: Contracts with third parties who violate this policy may be terminated, and legal action may be pursued.

9. Review and Amendments

This policy will be reviewed annually or as necessary to ensure it remains current and effective. Any amendments to the policy must be approved by the Board of Directors.