Anti-Corruption Policy & Ethics Compliance Program

At Investinu Group, we are committed to conducting our business in accordance with the highest ethical standards and in compliance with all applicable laws and regulations. This commitment is fundamental to the way we operate and underpins our corporate reputation and success. Our Anti-Corruption Policy and Ethics Compliance Program are designed to ensure adherence to the principles of integrity, transparency, and accountability across all our operations globally, particularly in compliance with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other relevant anti-corruption legislation in the jurisdictions where we operate.

This policy applies to all employees, officers, directors, and third parties acting on behalf of Investinu Group, including agents, consultants, contractors, and joint venture partners, irrespective of location, function, or role.

• U.S. Foreign Corrupt Practices Act (FCPA): We strictly prohibit any form of bribery, whether directly or indirectly, to foreign officials for the purpose of obtaining or retaining business or securing any improper advantage. We maintain rigorous internal controls and keep accurate records as required by the FCPA.
• UK Bribery Act: Beyond prohibiting bribery of public officials, we adhere to the UK Bribery Act’s broader prohibitions against bribery in the private sector. Our commitment extends to the prevention of facilitation payments, which are considered bribes under UK law, and we enforce a zero-tolerance policy towards such practices.
• Local Anti-Corruption Legislation: In addition to the FCPA and UK Bribery Act, we comply with all local anti-corruption laws in the jurisdictions where we operate. Our compliance framework is designed to be flexible and adaptable to accommodate the legal requirements of multiple jurisdictions.

Investinu Group maintains a strict policy against facilitation payments. We recognise that such payments, even if considered minor or routine in some jurisdictions, can undermine the integrity of our operations and conflict with our commitment to ethical business practices. Our policy explicitly prohibits the offering, promising, giving, or authorising of any form of facilitation payment, regardless of local customs or pressures. This stance is aligned with the strictest interpretations of anti-corruption laws globally, including the UK Bribery Act, which does not recognise an exception for facilitation payments.

Investinu Group has established a clear and comprehensive Gifts and Hospitality Policy, which is integral to our Anti-Corruption Policy and Ethics Compliance Program. This policy outlines the acceptable parameters for giving and receiving gifts and hospitality, ensuring they are not intended to influence business decisions or gain unfair advantage.

• Gifts: All gifts given or received by employees must be of nominal value, transparently recorded, and compliant with local laws and industry standards. Gifts must never be offered or accepted in exchange for favourable business treatment.
• Hospitality: Hospitality, including meals and entertainment, should be modest, directly related to legitimate business discussions, and should not exceed the bounds of reasonable business practice. Prior approval from management is required for hospitality exceeding set thresholds.

• Documentation and Approval: All gifts and hospitality given or received must be properly documented and, where necessary, approved in advance by the compliance department. This ensures transparency and adherence to policy guidelines.
• Training and Awareness: Employees and relevant third parties receive training on the Gifts and Hospitality Policy as part of our broader anti-corruption training efforts. This includes guidance on distinguishing acceptable practices from potential violations.
• Audits and Reviews: Regular audits and compliance reviews are conducted to monitor adherence to the Gifts and Hospitality Policy. Any discrepancies or violations are addressed promptly with appropriate corrective measures.
• Reporting Mechanisms: Employees are encouraged to report any concerns or violations of the Gifts and Hospitality Policy through established, confidential reporting channels. We ensure that all reports are investigated thoroughly and that confidentiality and protection from retaliation are maintained.

The leadership at Investinu Group unequivocally supports our Anti-Corruption Policy and Ethics Compliance Program, including our stance on gifts and hospitality. Our Board of Directors oversees the program, ensuring accountability and adherence at all levels of the organisation.

Integrity is at the core of Investinu Group’s values. We are dedicated to maintaining an ethical workplace and conducting business free from corruption. Our comprehensive Anti-Corruption Policy and Ethics Compliance Program, including our firm policies on facilitation payments and gifts and hospitality, reflects our unwavering commitment to legal compliance and ethical conduct worldwide.