ANTI-CORRUPTION POLICY

This Anti-Corruption Policy (hereinafter referred to as” Policy”) is effective from [INSERT DATE ON WHICH THE POLICY COMES INTO FORCE] and applies to all the employees of the [INSERT COMPANY NAME] (hereinafter referred to as “Us” or “we” or “Company”).

This policy outlines the clear standards and principles to be followed by every employee of the company, ensuring a harmonious and respectful environment. By upholding these values, we can collectively contribute to the success of our company and maintain the trust and confidence of our clients, partners, and colleagues.

1. PURPOSE
   1. The goal of this policy serves as a roadmap for our actions, reflecting our highest standards of commitment to preventing and detecting corruption in all forms within the Company. We encourage our employees to familiarize with the guidelines outlined in this policy and to seek guidance when facing ethical dilemmas. This policy aims at maintaining an inclusive, safe and productive workplace for every working individual in our company.
2. SCOPE
   1. This policy applies to all employees, including full-time, part-time, temporary, at all levels within the Company. The scope of this policy is not limited to just work-place but also to work related functions in events or other functions that may impact the Company’s name and reputation. In circumstances where an employee’s behavior or conduct may involve a breach of this policy. The Company might take disciplinary, or termination actions based upon the set guidelines in this policy.
3. POLICY STATEMENTS
   1. We are committed to conducting business with the highest levels of integrity and transparency. Corruption undermines the trust we have with our stakeholders and the communities we serve. Therefore, all employees are required to adhere to strict anti- anti-corruption standards.
   2. Prohibition of Corruption: Employees must not offer, promise, or provide anything of value, directly or indirectly, to any individual or entity to gain an unfair advantage or improperly influence a business decision. Likewise, employees must not solicit or accept bribes or other inappropriate benefits.
   3. Accurate Records and Reporting: All financial transactions and records must be accurate, complete, and transparent. Falsification, alteration, or unauthorized access to company records is strictly prohibited.
   4. Gifts, Entertainment, and Hospitality: Employees must exercise caution when giving or receiving gifts, entertainment, or hospitality. Such gestures must be modest, in line with industry norms, and must not create an obligation that could compromise impartiality.
   5. Third-Party Due Diligence: Before entering into business relationships with third parties, such as vendors, suppliers, or partners, employees must ensure that these entities uphold similar anti-bribery and anti-corruption standards.
4. ENHANCED DUE DILIGENCE (EDD)
   1. Company will conduct enhanced due diligence, using a risk based approach to address events with a high possibility of corruption or other major financial crimes.
   2. Company will conduct a more detailed and thorough investigations during EDD, requiring additional documentation including site visits, third-party verification and enhanced transaction monitoring.
5. RISK ASSESSMENT
   1. Company will conduct potential risk assessments to identify and evaluate the risks that could impact the Company’s financial and operational activities.
   2. Company will analyze and document all the risks associated within and outside the Company and will take necessary steps to mitigate those risks.
   3. Company will ensure that all risk assessments align with applicable financial regulations and industry standards.
   4. Company will conduct monitoring mechanisms to track the effective implementation of risk mitigation strategies.
6. ONGOING MONITORING
   1. Company will periodically review Client’s information and financial activities to ensure it remains current and accurate.
   2. Our Company will implement periodic assessments of customer risk profiles based on evolving business transactions and activities.
7. REPORTING SUSPICIOUS ACTIVIES
   1. All Employees have a responsibility to promptly report any suspicious activities they encounter or become aware of during the course of their duties, to the Company.
   2. Company will investigate the reported activity to determine if they warrant further action, including filing suspicious activity with the appropriate authorities.
   3. All Suspicious Activity reports and related information will be kept confidential to the extent required by law and used solely for the required purposes.
   4. Company will take reasonable measures to protect employees involved in reporting suspicious activities from potential threats or retaliation.
8. TRAINING AND DEVELOPMENT
   1. We will provide regular training and awareness programs to ensure that all new employees, contractors, and other stakeholders are aware of the corruption policy and importance of combating corruption.
   2. New Employees participating in training and development activities are expected to comply with this and all other relevant company policies.
9. COMPLIANCE AND REPORTING

9.1 Compliance with this policy and applicable laws should be regularly monitored and audited to identify and address any potential gaps or non-compliance. Any identified breaches or non-compliance should be promptly investigated, and appropriate corrective actions should be taken.

1. CHANGES TO THE POLICY

10.1 We reserve to right to update and make changes to this policy from time to time based on the working conditions of the Company. The Company on updating this policy will inform the members of the Company.

1. FURTHER INFORMATION

11.1 For any queries or further Information regarding our Company or about this Policy, the concerned person can contact us through email [INSERT EMAIL ADDRESS OF THE COMPANY]

1. ACKNOWLEGEMENT

12.1 We expect all employees to adhere to this policy of the Company. The Company will apply this policy consistently and fairly to ensure a harmonious and productive workplace for all.

12.2 By signing below, you acknowledge that you have carefully read and understood the terms and contents of this policy.

12.3 You acknowledge that you will follow the set guidelines of this policy as well as of the Company and failure to do so, the Company can take Disciplinary action against such person.

COMPANY                  

[INSERT NAME OF THE COMPANY]

AUTHORIZED SIGNATURE