Apiso (herein after referred as “Company”) is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Company’s behalf is responsible for maintaining the Company’s reputation and for conducting business honestly and professionally. The Company considers that bribery and corruption have a detrimental impact in business by undermining good governance and distorting free markets.

The Company benefits from carrying out business in a transparent and ethical way. It does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any person or companies acting for it or on its behalf. The Board and senior management are committed to implementing and enforcing effective systems to prevent and eliminate bribery, in accordance with the Bahrain Penal Code (Law No.1/2013) cover the offence of bribery in the private sector and United Nations Convention against Corruption in Law (“UNCAC”), which has been implemented under Law No.7/2010.

The Company has issued an anti-bribery and corruption policy, which contains information on gifts and corporate hospitality, outlining the Company’s position on preventing and prohibiting bribery and corruption. This Policy applies to all employees and they are required to familiarize themselves and comply accordingly.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly. Employees and others acting for or on behalf of the Company are strictly prohibited from making, soliciting, or receiving any bribes or unauthorized payments. As part of its anti-bribery measures, the Company accepts transparent, proportionate, reasonable, and bona fide hospitality and promotional expenditure, whether given or received.

A breach of this Policy by an employee will be treated as grounds for disciplinary action. Employees and other individuals acting for the Company should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and fines shall also apply to offenders, equivalent to the amount of the bribe requested, accepted, promised or offered, subject to a minimum fine of BD 100 in the public sector and a minimum of BD500 capped at BD10,000 in the private sector.

The Company has a policy of not conducting business with service providers, agents or representatives that do not support appropriate anti-bribery and corruption objectives. The success of the Company’s anti-bribery and corruption measures depends on all employees, and those acting for the Company, playing their part in helping prevent bribery. Therefore, all employees and others acting for, or on behalf of, the Company are encouraged to report any suspected bribery in accordance with the procedures set out in the Policy or in the case of third parties to the Head of Compliance at the Company. The Company will support any individuals who make such a report in good faith.