Anti Bribery Policy

United against corruption, we stand stronger

Overview:

Each individual bears the responsibility for preventing, detecting, and reporting instances of bribery. If you have any concerns or suspicions regarding bribery, it is imperative that you report them to either your immediate supervisor or you may opt to adhere to the Whistleblowing Policy. A copy of this policy is available for reference on the notice board on the Company’s intranet. Additional copies can be acquired from the Company Secretary. The act of providing or accepting a bribe, which leads to personal benefit or advantage for oneself, another party, or an organization, or is designed to exert influence, is strictly forbidden. This encompasses the act of offering or attempting to offer illicit incentives to a foreign government official, with the specific aim of acquiring or maintaining business opportunities.

Policy Purpose:

The objective of this policy is to function as a comprehensive directive for all personnel. This document outlines the necessary procedures to uphold the Company’s principles, comply with corporate responsibilities, and meet social and legal expectations.

Policy:

It is strictly prohibited to engage in any form of bribery, whether by offering, giving, soliciting, or accepting bribes in cash or any other form of inducement. This applies to individuals or companies, regardless of their location or whether they are public officials or private entities. Furthermore, it is forbidden to obtain any commercial, contractual, or regulatory benefits for the Company in a manner that may be considered unethical.

Responsibility:

This policy is applicable to all staff members, irrespective of their level of seniority.

Gifts & Hospitality:

When gifts and hospitality are overly abundant, they can be considered as a bribe and/or a conflict of interest. The value of such gifts and hospitality should not exceed the standard or customary standards in our industry. It is generally advisable to avoid them when contracts are being offered or granted. It is necessary to document all presents and entertainment in a dedicated register.With the exception of low-value gifts that are merely symbolic, such as promotional pens, calendars, and stationary, workers are prohibited from accepting any presents from customers, suppliers, or third parties associated with the Company. If declining a present could potentially cause offense or embarrassment, it is permissible to accept the gift and subsequently donate it to a charity selected by the Company. Prior authorization must be obtained from the Operations Manager or an individual of equal authority before taking any present. However, it is strictly prohibited to offer or receive cash as a gift under any circumstances.

‘Corporate Hospitality’ is described as the provision of accommodation, entertainment, or other forms of hospitality only for an employee because of their role as a representative of the Company. The following activities are excluded from the definition of Corporate Hospitality and do not necessitate any approval: Standard working lunches or refreshments offered during a business visit, hospitality provided at a company-sanctioned seminar or industry events such as our annual dinners or employee awards, as long as the hospitality is offered to all participants, complimentary seminars, talks, or workshops, provided they are free for all attendees, all other types of Corporate Hospitality must receive approval from the Operations Manager or equivalent before being accepted. It is important to keep in mind that market practices differ among countries, and what is considered normal and acceptable in one place may not be the same in another. If you have any uncertainty regarding the suitability of a gift or hospitality, please see the Company Secretary.

Policy Breach:

The AMI Group of Companies will thoroughly investigate any confirmed or suspected violation of this policy or its underlying principles. Employees may face disciplinary measures that could potentially lead to their termination. If any third parties are discovered to have engaged in bribery or attempted bribery of our employees, senior officers, suppliers, or customers, they will be notified in writing that all commercial transactions will be terminated, and the relevant authorities will be notified.