ANTI-BRIBERY & CORRUPTION

(ABC) Policy


1. POLICY STATEMENT

SPLENDID A D S GROUP (“SPLENDID”) maintains a zero-tolerance stance toward bribery and corruption, complying with all applicable anti-corruption and anti-bribery laws, including the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act (FCPA), and other relevant international legislation in jurisdictions where SPLENDID operates.

2. Purpose and Scope

This policy applies to all SPLENDID employees and third parties acting on its behalf. It ensures ethical conduct and compliance with legal obligations in all operational territories.

3. Definitions

• Bribery: Offering or receiving anything of value to influence a decision.

• Facilitation Payments: Prohibited unofficial payments to speed up routine processes.

• Gifts & Hospitality: Must be modest, occasional, and properly recorded.

• Conflict of Interest: Situations where personal interests conflict with professional duties.

4. Gifts, Entertainment, and Hospitality

Business courtesies must not influence decisions. Gifts over an approved threshold require pre-approval and must be logged in the company register.

5. Political and Charitable Contributions

No political donations are allowed. Charitable donations must be legitimate, transparent, and properly documented.

6. Third Parties and Due Diligence

Suppliers, agents, and contractors must adhere to this policy and undergo due diligence. Contracts must include anti-corruption clauses and permit compliance audits.

7. Reporting Violations (Whistleblowing)

Suspected violations can be reported confidentially to ethics@splendidad.com. SPLENDID enforces a non-retaliation policy for whistleblowers.