Compliances

1. Anti-Corruption Compliance

1.1 Prohibition of Corruption and Bribery
• We strictly prohibit offering, promising, giving, or accepting bribes or other improper payments to or from any person or entity, including government officials, customers, vendors, or business partners.
• Facilitating payments intended to expedite or secure routine governmental actions is not allowed.

1.2 Due Diligence Before engaging third parties, business partners, or agents, thorough due diligence must be conducted to ensure they uphold anti-corruption standards consistent with this policy.

2. Business Ethics

2.1 Integrity and Honesty All business transactions must be conducted with integrity and honesty. Employees must avoid conflicts of interest and disclose any potential or actual conflicts to their manager or the compliance team.

2.2 Fair Competition Employees must adhere to all applicable antitrust and competition laws. Unethical practices such as price-fixing, market allocation, or bid rigging are strictly forbidden.

3. Payment of Commission

3.1 Legitimate Payments Only
• Commissions, fees, or other payments to third parties must be legitimate and documented in writing.
• Payments must be commensurate with the services provided and approved by senior management.

3.2 Prohibition of Improper Payments Payments made to secure or reward an improper advantage are strictly prohibited. Payments must never be disguised or misclassified in financial records.

4. Gifts and Entertainment

4.1 Acceptable Practices
• Employees may offer or accept gifts, meals, or entertainment only if they are lawful, reasonable in value, and not intended to influence a decision improperly.
• Gifts must be consistent with local cultural norms and business practices.

4.2 Government Officials
• Gifts or entertainment to government officials must have prior written approval from the compliance team.
• Strictly avoid actions perceived as attempts to influence government decisions improperly.

4.3 Record Keeping All gifts and entertainment provided or received must be documented and reported to the compliance team for review.

5. Reporting and Accountability

5.1 Reporting Violations Employees must promptly report any suspected violations of this policy to their manager or through the whistleblower hotline. Retaliation against individuals who report in good faith is strictly prohibited.

5.2 Internal Investigations All reported violations will be investigated thoroughly and impartially. Corrective actions, including disciplinary measures, will be taken where necessary.

6. Training and Awareness

6.1 Mandatory Training All employees must complete annual anti-corruption and business ethics training to understand their responsibilities under this policy.

6.2 Ongoing Communication We will regularly communicate updates and reminders about compliance requirements to employees and stakeholders.

7. Record Keeping

7.1 Accurate Records All financial transactions must be recorded accurately and transparently. Records must reflect the true nature of the transaction and comply with all applicable laws and regulations.

7.2 Retention Policy Documents related to anti-corruption compliance must be retained for a minimum of five years or longer if required by law.

8. Consequences of Non-Compliance

8.1Violations of this policy may result in disciplinary actions, including termination of employment or business relationships, and may also lead to legal consequences for individuals and the organization.

9. Policy Review and Updates

This policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, or business practices.