Company Policy on Anti-Corruption, Anti-Bribery, and Fair Competition

V. 2024_06_01

At iNovaland, we are steadfast in our commitment to conducting business with integrity, transparency, and accountability. We recognize that corruption and bribery not only undermine economic development and erode trust but also distort fair competition. Therefore, we adhere to the principles outlined in the United Nations Convention against Corruption (UNCAC) and have established robust policies to combat corruption and bribery while promoting fair competition in all our operations. Our policies are as follows:

1. Zero-Tolerance Policy: We maintain a zero-tolerance stance towards corruption and bribery in any form, whether involving public officials, private entities, or individuals. Any employee found engaging in such activities will face disciplinary action, up to and including termination, in accordance with applicable laws and regulations.
   
   
2. Compliance with Laws, Regulations, and Fair Competition Principles: We comply with all relevant anti-corruption laws, regulations, and international standards, including the UNCAC and local legislation in the countries where we operate. Additionally, we uphold fair competition principles and adhere to antitrust regulations to ensure a level playing field in the marketplace. We require our employees, agents, representatives, and business partners to adhere to these laws, regulations, and fair competition principles without exception.
   
   
3. Gifts, Entertainment, and Hospitality: We prohibit the offering, giving, solicitation, or acceptance of gifts, entertainment, or hospitality that could be perceived as intended to improperly influence business decisions, gain an unfair advantage, or violate antitrust regulations. Any such exchanges must be modest, transparent, and in compliance with our company policies, applicable laws, and fair competition principles.
   
   
4. Conflict of Interest: We expect our employees to avoid situations where personal interests conflict with their responsibilities to the company. Any potential conflicts of interest must be disclosed promptly and managed appropriately to prevent undue influence, favouritism, or violations of fair competition principles.
   
   
5. Due Diligence on Business Partners: We conduct thorough due diligence on our business partners, including suppliers, contractors, agents, consultants, and distributors, to ensure they share our commitment to anti-corruption, anti-bribery principles, and fair competition. We enter into contractual agreements that include anti-corruption clauses, provisions for monitoring compliance, and adherence to fair competition principles. 
   
   
6. Reporting and Whistleblowing: We encourage employees to report any suspected instances of corruption, bribery, or violations of fair competition principles promptly and confidentially through established channels, such as our whistleblower hotline or designated compliance officers. We prohibit retaliation against individuals who report such concerns in good faith.
   
   
7. Training and Awareness: We will provide regular training and awareness programs to our employees and relevant stakeholders to enhance their understanding of anti-corruption laws, policies, ethical standards, and fair competition principles. We empower them to recognize and resist situations that may involve corruption, bribery, or unfair competition
   practices.
8. Monitoring and Review: We will conduct periodic reviews and assessments of our anti-corruption, anti-bribery, and fair competition controls to identify weaknesses, gaps, or areas for improvement. We take corrective actions as necessary to strengthen our compliance framework, mitigate risks effectively, and ensure adherence to fair competition principles.
   
   
9. Transparency and Reporting: We strive to maintain transparency in our business practices and financial transactions, including disclosing relevant information to regulatory authorities, stakeholders, and the public as required by law, best practices, and fair competition principles.
   
   
10. Continuous Improvement: We are committed to continuously improving our anti-corruption, anti-bribery, and fair competition efforts through regular evaluation, benchmarking against industry standards, and collaboration with relevant stakeholders.

At iNovaland, we believe that combating corruption, bribery, and promoting fair competition is essential for fostering trust, integrity, and sustainability in business. By adhering to these policies and principles, we demonstrate our dedication to ethical conduct, responsible corporate citizenship, and a level playing field for all market participants.

This policy applies to all employees, contractors, suppliers, and other stakeholders associated with iNovaland and is communicated to them through various channels, including our website, employee handbooks, training programs, and contractual agreements.