Anti-Bribery and Anti-Corruption Policy

Introduction:
Our company is committed to conducting business with the highest ethical standards and integrity. We strictly adhere to all applicable laws and regulations related to anti-bribery and anti-corruption, including the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. This policy outlines our stance against bribery and corruption and sets clear guidelines for all employees, contractors, suppliers, and business partners to follow.

Prohibition of Bribery:
Bribery in any form is strictly prohibited. This includes offering, promising, giving, soliciting, or accepting any form of improper advantage, whether in cash, gifts, entertainment, or other benefits, to influence business decisions or gain an unfair advantage. We do not tolerate any actions that compromise the principles of fair competition and transparency.

Business Gifts and Hospitality:
Gifts and hospitality offered or received in the course of business dealings must be reasonable, proportionate, and consistent with local customs and practices. Employees must not offer or accept gifts, entertainment, or favors that could influence or be perceived to influence their business decisions. All such exchanges must be transparent and properly recorded.

Relationships with Public Officials:
Our company maintains a strict policy when dealing with public officials and government representatives. Any interactions with them must comply with all applicable laws and regulations. Employees must not offer or provide any improper benefits to public officials to secure business advantages.

Due Diligence on Business Partners:
Before engaging in any business relationship with third parties, including suppliers, agents, distributors, and consultants, a thorough due diligence process must be conducted. This process helps identify and mitigate any potential risks related to bribery and corruption.

Record-Keeping:
Accurate and transparent record-keeping is essential to combat bribery and corruption effectively. All transactions and business activities must be properly documented and recorded in accordance with our company’s policies and relevant laws.

Reporting and Whistleblowing:
We encourage all employees, contractors, and stakeholders to report any suspected or actual instances of bribery or corruption promptly. Our company provides a confidential and secure whistleblowing mechanism for reporting such concerns. Retaliation against individuals reporting in good faith is strictly prohibited.

Training and Awareness:
Regular training and awareness programs are conducted to ensure all employees and relevant parties understand the policy and their obligations regarding anti-bribery and anti-corruption practices.

Compliance and Consequences:
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or business relationships. Additionally, individuals involved in bribery or corrupt activities may face legal prosecution and personal liability.

Continuous Improvement:
Our company is committed to continuous improvement in preventing bribery and corruption. We regularly review and update this policy to reflect changes in laws, regulations, and best practices. By adhering to this Anti-Bribery & Anti-Corruption Policy, we reinforce our commitment
to ethical business practices and contribute to a corruption-free business environment.