ANTI-BRIBERY AND CORRUPTION (ABC) POLICY / CODE OF BUSINESS CONDUCT

INTRODUCTION:
Our Company is committed to conducting its business ethically and in compliance with all applicable laws and
regulations that prohibit bribery and corruption to obtain a business advantage. This document describes our
company policy prohibiting bribery, corruption and other related practices in the conduct of our operations. This
policy covers, but not limited to:
1. PROHIBITION OF BRIBERY AND CORRUPTION
No bribes of any sort may be solicited from, paid to or accepted from customers, suppliers, agents, consultants,
intermediaries, joint ventures or other business partners, stakeholders, politicians, and/or government officials. For
all intents and purposes, Company has a zero-tolerance for any form of bribery and corruption with regards to:

1.1 AGENTS, INTERMEDIARIES, CONTRACTOR & SUPPLIERS

When retaining, paying or working with an Agent Intermediary, Contractor and Suppliers we undertake to:
 Implement proper documented due diligence.
 Have a solid, documented basis for trusting the intermediary.
 Implement measures to monitor and prevent misconduct
 Ensure that our agents, intermediaries, contractors & suppliers are aware of our ABC Policy and zero
tolerance for bribery and corruption in our business operations.

2. RULES ON GIFTS AND HOSPITALITY

Company prohibits offering, promising or giving anything of value in order to obtain an improper business
advantage. These includes, but not limited to the following:
 Gifts, entertainment or other business promotional activities
 Covering or reimbursing a public official’s expenses
 Offers of employment or other benefits to a family member or friend of a public official

3. FACILITATION PAYMENTS, SPONSORSHIP AND DONATIONS

Our Company is very mindful of its Corporate Social Responsibilities.
Charitable donations and sponsorships must not be used as a subterfuge for bribery and must be consistent with
Company’s ABC Policy.

4. PREVENTION AND SANCTIONS

 The Company’s human resources shall implement programs which includes but not limited to
training/certification, documentation and records that reflects Company's commitment to this ABC Policy.

 Sanctions for breach of company policy includes termination of employment or appointment, suspension or
severance of business relationship with clients/customers and may lead to civil or criminal proceedings
against defaulters.

Signed by:

CEO/MD