> Ethics & Code of Conduct Policy
Purpose and Statement of Commitment
Kausora Technologies ("Kausora" or "the Company") is fully committed to conducting business with the highest standards of integrity and has zero tolerance for any form of bribery or corruption. This Ethics & Code of Conduct Policy establishes our commitment to ethical business practices and ensures compliance with all applicable anti-bribery and anti-corruption laws worldwide, including the United Arab Emirates (UAE) anti-corruption laws, the UK Bribery Act 2010, and the U.S. Foreign Corrupt Practices Act (FCPA).
These laws generally prohibit offering or accepting bribes, kickbacks, or improper payments to influence business decisions and require companies to maintain accurate books and records.
Scope and Applicability
This Policy applies globally to all Kausora Technologies employees, officers, and directors, as well as to third parties associated with Kausora. This includes permanent and temporary employees at all levels, contractors, consultants, agents, representatives, suppliers, vendors, joint-venture partners, and any other external parties performing work or services on behalf of Kausora.
Definitions and Examples of Prohibited Conduct
Bribery
Bribery is defined as the offer, promise, giving, solicitation or acceptance of any financial or other advantage (anything of value) as an inducement for an action that is unethical, illegal, or a breach of trust.
Corruption
Corruption is the abuse of entrusted power or breach of trust for private gain. This includes any form of dishonest or improper behavior intended to secure an unfair advantage.
Facilitation Payment
A facilitation payment is a small unofficial payment made to a public official to expedite or secure the performance of a routine governmental action. Under this Policy, all facilitation payments are prohibited.
Public Official
The term includes any officer or employee of a government department or agency, any person acting in an official capacity for a government, any political party or party official, any candidate for public office, employees of state-owned or state-controlled enterprises, public international organizations, or members of royal families.
Gifts and Hospitality
Business gifts, meals, travel, entertainment and hospitality can build goodwill, but they can also be misused as bribes. As a general rule, Kausora employees and representatives must not offer or accept gifts or hospitality that could improperly influence a business decision or create a sense of obligation. All gifts and hospitality must be modest, infrequent, and transparent.
Guidelines
- Nominal Value Limit: Gifts should not exceed US $50 per recipient
- Government Officials: Only very small token gifts (under US $25) are permissible
- Cash Prohibited: Cash gifts or cash equivalents (gift cards) are strictly prohibited
- Excessive Hospitality: Entertainment or hospitality exceeding US $250 per person per event requires written pre-approval
- Transparency: All gifts and hospitality expenses must be fully documented and correctly recorded
Charitable Donations and Sponsorships
Kausora Technologies recognizes the importance of charitable giving and community involvement. However, donations and sponsorships can be abused as a cover for bribery, so strict controls are in place. No donation or sponsorship may be offered or made with the intent of obtaining an improper business advantage.
- All charitable contributions require prior written approval
- Due diligence must be conducted on recipient organizations
- All donations must be accurately recorded and documented
- Post-donation monitoring to ensure proper use of funds
Facilitation Payments
Facilitation payments are strictly prohibited by Kausora's policy. A facilitation (or "grease") payment is typically an unofficial, minor payment to a low-level government employee to speed up or secure a routine, non-discretionary administrative action.
All persons covered by this Policy should politely refuse any request or demand for a facilitation payment and immediately report the incident to the Compliance Officer.
Conflict of Interest Disclosure
All employees, officers, and associated parties of Kausora must perform their duties objectively and in the best interests of the Company. A conflict of interest arises when an individual's personal interests interfere, or appear to interfere, with their ability to make impartial decisions on behalf of the Company.
Common Examples
- Having a significant financial interest in a competitor, supplier, or customer
- Directing Company business to a firm owned by a family member or close friend
- Employment or consulting outside Kausora that affects objectivity
- Hiring or supervising a family member or someone with a close personal relationship
- Receiving personal benefits or kickbacks from a vendor
Third-Party Relationships and Due Diligence
Kausora's commitment to anti-corruption extends to all third parties with whom we do business. The Company can be held liable for improper payments or bribes made by third parties acting on our behalf.
Key Requirements
- Due Diligence: Conduct risk-based due diligence before engaging third parties
- Contractual Controls: Include anti-bribery clauses and representations in agreements
- Payments and Compensation: Ensure all payments are for legitimate services and properly documented
- Monitoring: Continue to monitor actions of key third parties after engagement
Reporting Violations and Whistleblower Protection
All Kausora personnel and partners have a responsibility to speak up if they suspect or become aware of any violation of this Policy or any unethical or illegal conduct.
Reporting Channels
- Your Manager or Department Head
- Compliance Officer or Legal Department
- Human Resources
- Whistleblower Hotline (anonymous reporting available)
- Board Audit Committee
Whistleblower Protection – No Retaliation: Kausora strictly prohibits any form of retaliation against anyone who in good faith reports a concern or assists in an investigation.
Investigation and Disciplinary Action
Kausora takes all reports of potential misconduct seriously. The Company will investigate promptly and fairly any suspected violation of this Ethics & Code of Conduct Policy or other ethical standards.
Disciplinary actions for employees who violate this Policy can include: verbal or written warnings, mandatory training, suspension, demotion, and up to immediate termination of employment for serious offenses.
Roles and Responsibilities
- Board of Directors and Executive Management: Demonstrate visible commitment and ensure resources are provided
- Compliance Officer: Administer the Policy, provide guidance, conduct investigations
- Managers and Supervisors: Communicate and implement Policy, lead by example
- Human Resources: Incorporate anti-corruption into hiring and personnel processes
- Finance and Accounting: Maintain internal financial controls and accurate records
- All Employees: Understand and comply with Policy, participate in training, report violations
Training and Awareness
Effective ethical compliance requires continuous education and awareness. All Kausora employees must complete Ethics & Code of Conduct training covering anti-corruption, conflicts of interest, and ethical decision-making. New hires will receive training as part of their orientation, and all employees will participate in refresher training at least annually.
Conclusion
Kausora Technologies requires all employees and partners to perform their duties with honesty and integrity. Bribery and corruption are not just against Company policy – they are illegal and incompatible with our values. By following the guidelines in this Ethics & Code of Conduct Policy, each of us contributes to a culture of transparency and trust, protects the Company's reputation, and helps ensure our ongoing success in a lawful and ethical manner.
Please direct any questions about this Ethics & Code of Conduct Policy to the Compliance Officer or the Legal Department.
Contact: contact@kausora.com