Our company maintains a comprehensive Code of Conduct and Business Ethics Policy, which includes explicit procedures and standards related to anti-corruption compliance, payment of commissions, gifts and entertainment, and ethical interactions with customers and Government Officials. Key elements include:

1. Anti-Corruption Compliance
   We maintain a zero-tolerance policy toward bribery and corruption in all business dealings, in accordance with applicable laws such as the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and relevant local legislation. Employees and third parties acting on our behalf are prohibited from offering, promising, giving, or authorizing anything of value—whether directly or indirectly—to any Government Official or private party to improperly influence a business decision.

2. Payment of Commissions and Third-Party Due Diligence
   We require enhanced due diligence and approval before engaging agents, consultants, or intermediaries, especially in high-risk jurisdictions. All commission arrangements must be documented in writing, proportionate to services rendered, and subject to legal and compliance review to ensure they do not constitute disguised bribes.

3. Gifts, Hospitality, and Entertainment
   Our policy permits modest and reasonable gifts or entertainment as part of legitimate business relationship-building, provided they:

   • Are not frequent or excessive;

   • Are not intended to improperly influence a business decision;

   • Comply with local law and the recipient’s internal policies;

   • Are reported and, where required, pre-approved by compliance or management.

   Gifts or hospitality to Government Officials are subject to strict limits and generally discouraged unless required for legitimate ceremonial or cultural reasons, with prior written approval.

4. Training and Monitoring
   All employees receive mandatory training on business ethics and anti-corruption topics. We conduct periodic audits and risk assessments, and maintain confidential reporting channels for concerns or suspected violations.

5. Enforcement and Disciplinary Measures
   Violations of our anti-corruption or ethics policies may result in disciplinary action, up to and including termination of employment or contract, and may be reported to authorities when appropriate.

A copy of our full Code of Conduct or Anti-Corruption Policy can be provided upon request.

​