Anti-Bribery & Corruption Policy

Introduction

Qico ("the Company") is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including anti-bribery and corruption laws. This Anti-Bribery and Corruption Policy outlines our stance against bribery and corruption and sets forth the responsibilities of our employees, contractors, and partners in maintaining the highest standards of integrity.

Purpose

The purpose of this policy is to:

Ensure compliance with applicable anti-bribery and corruption laws and regulations.
Provide guidance on recognizing and dealing with bribery and corruption.
Promote a culture of honesty and integrity within the Company.

Scope

This policy applies to all employees, contractors, consultants, agents, and any other third parties acting on behalf of Qico, regardless of their location.

Prohibition of Bribery and Corruption

QICO strictly prohibits any form of bribery or corruption, whether direct or indirect.
No employee or associated person shall offer, give, solicit, or receive any bribe or inducement, whether in cash or any other form, to or from any person or organization.

Gifts and Hospitality

The Company permits normal and appropriate hospitality and gifts, provided that they are reasonable, not extravagant, and intended to maintain good business relationships.
All gifts and hospitality must be reported and recorded in the Gifts and Hospitality Register.
Gifts or hospitality must not be offered or accepted if they could influence, or appear to influence, business decisions or violate any laws or regulations.

Facilitation Payments

Facilitation payments are unofficial, small payments made to expedite routine government actions. Qico prohibits making or accepting facilitation payments of any kind.
Any request for a facilitation payment must be reported to the Compliance Officer immediately.

Third Parties

Qico expects all third parties acting on its behalf to adhere to the same standards of anti-bribery and corruption.
Due diligence must be conducted on third parties to ensure their compliance with anti-bribery and corruption laws.
Contracts with third parties must include clauses that mandate compliance with this policy.

Charitable Contributions and Sponsorships

Charitable donations and sponsorships must be transparent, legal, and ethical. They should not be made to gain an improper business advantage.
All contributions must be reviewed and approved by the Compliance Officer.

Political Contributions

Qico does not make political contributions. Employees and associated persons must not use company funds for political donations.

Responsibilities

Employees and Associated Persons:
- Must read, understand, and comply with this policy.
- Must report any suspected or actual breaches of this policy to the Compliance Officer.
Compliance Officer:
- Responsible for implementing and monitoring compliance with this policy.
- Conducts regular risk assessments and audits to ensure adherence to anti-bribery and corruption laws.
- Provides training and guidance on anti-bribery and corruption to all employees and associated persons.

Reporting and Whistleblowing

Employees and associated persons are encouraged to report any concerns or suspicions regarding bribery or corruption. Reports can be made to the Compliance Officer or through the Company’s whistleblowing hotline. All reports will be treated confidentially and investigated promptly.

Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, including termination of employment or contractual agreements. In addition, individuals may be subject to legal penalties under applicable anti-bribery and corruption laws.

Review and Amendments

This policy will be reviewed regularly and updated as necessary to ensure its effectiveness and compliance with applicable laws and regulations.

Contact Us

For questions or further information regarding this policy, please contact us.