Anti-Corruption Policy

Anti-Corruption Policy

The Anti-Corruption Policy establishes principles and standards designed to prevent violations of applicable anti-bribery laws and regulations.

Company prohibits bribery and corruption in all forms. This includes authorizing, offering, or paying bribes; demanding, taking or receiving bribes; engaging in bribery through third party intermediaries, service providers and business partners; engaging in public or private sector bribery; and bribery in connection with any transaction to which Company is a party, either by itself or with/ through others. Violations of applicable anti-bribery laws may result in criminal, civil and regulatory penalties for the Company, including fines or disgorgement of profits.

Individual employees may also be subject to criminal, civil or regulatory penalties, including fines, disgorgement of profits or imprisonment. In addition, actual and/or perceived violations of antibribery laws could cause damage to Company’s reputation.

CONTENT

1. OVERVIEW
1.1 PROCEDURE OWNER
1.2 CLASSIFICATION
1.3 APPLICABLE REGULATIONS
1.4 RELATED [COMPANY] NORMS AND PROCEDURES
1.5 OBJECTIVES
1.6 AUDIENCE AND SCOPE
1.7 DOCUMENT SUPPORT
2. DEFINITIONS & ABBREVIATIONS
3. ROLES AND RESPONSIBILITIES
4. APPLICABLE LAWS
5. EMPLOYEE RISK: OFFERING, PROVIDING OR RECEIVING BENEFITS OR OTHER ADVANTAGES
5.1 GOVERNMENT OFFICIALS
5.2 PRE-APPROVAL REQUIREMENTS
5.3 PROHIBITED PAYMENTS
5.4 BOOKS AND RECORDS
6. THIRD PARTY RISK: THIRD PARTY INTERMEDIARIES, SERVICE PROVIDERS AND BUSINESS PARTNERS
6.1 DUE DILIGENCE AND APPROVAL OF RELATIONSHIPS
6.2 WARNING SIGNS OF BRIBERY AND RELATED ILLEGAL CONDUCT BY THIRD PARTIES
6.3 WRITTEN AGREEMENTS WITH THIRD PARTIES
6.4 CLIENT RISK: THE RISK OF CLIENTS USING THE COMPANY TO FACILITATE BRIBERY
7. REPORTING BRIBERY
8. EXCEPTIONS
9. FINAL CONSIDERATIONS
9.1 DISCIPLINARY ACTIONS AGAINST PROCEDURE VIOLATION
9.2 DOCUMENT REVISION

Pages: 15

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