Anti-Corruption and Anti-Bribery Policy

Anti-Corruption and Anti-Bribery Policy at Right People Group

Introduction

Right People Group is committed to conducting its business with the highest standards of integrity and in compliance with all applicable laws and regulations. This Anti-Corruption and Anti-Bribery Policy outlines our commitment to preventing corruption and bribery in all aspects of our operations.

Scope

This policy applies to all employees of Right People Group and related holdings, daughter and sister-companies as well as any other parties associated with Right People Group, collectively referred to as "Personnel."

Definition of Corruption and Bribery

Corruption and bribery are unacceptable practices that involve the offer, payment, receipt, or solicitation of anything of value to influence the actions of an official or other person in a position of trust. This includes but is not limited to cash, gifts, travel, entertainment, and any other form of undue advantage.

Compliance with Laws and Regulations

Right People Group and its Personnel shall comply with all applicable anti-corruption and anti-bribery laws and regulations in the jurisdictions in which we operate. Personnel are expected to be familiar with and adhere to these laws.

Prohibited Practices

No personnel shall offer, give, receive, or solicit bribes or any form of improper payment.

No personnel shall engage in corrupt practices, including but not limited to extortion, embezzlement, and money laundering.

No personnel shall use intermediaries for the purpose of facilitating bribes or corrupt practices.

Gifts, Hospitality, and Entertainment

While the exchange of gifts, hospitality, and entertainment is a common business practice, it should not be used as a means to gain undue influence or advantage. Personnel should exercise caution and obtain approval before offering or accepting such items.

Facilitation Payments

Facilitation payments, also known as "grease payments," are typically small payments made to facilitate routine government actions. Such payments are strictly prohibited unless explicitly allowed by local law and approved by the Compliance Officer.

Record Keeping

Accurate and transparent record-keeping is essential. All transactions must be properly recorded in the company's books and records, and no undisclosed or unrecorded account shall be established for any purpose.

Reporting Violations

Personnel are encouraged to promptly report any known or suspected violations of this policy to their supervisor or the designated Compliance Officer. Note to option to contact a 3rd party contact person in the Grievance Handling Policy.

Consequences of Violations

Violations of this policy may result in disciplinary action, up to and including termination of employment or contract, and may also lead to legal proceedings.

Review and Update

This policy will be reviewed periodically to ensure its effectiveness and relevance. Changes may be made as necessary to address emerging risks and challenges.

By adhering to this Anti-Corruption and Anti-Bribery Policy, we contribute to creating a workplace environment that upholds the highest ethical standards, fostering trust and integrity in all our business dealings.