S4D Compliance Policy: Anti-Corruption, Business Ethics, Payments, Gifts, and Entertainment

1. Introduction
Systems for Development (S4D) is committed to conducting business with the highest integrity, transparency, and ethical behavior standards. This policy establishes guidelines to ensure compliance with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other relevant regulations governing business conduct, payment of commissions, and interactions with customers and Government Officials.

2. Anti-Corruption Compliance
S4D strictly prohibits any form of bribery, corruption, or unethical business practices. Employees, contractors, consultants, and third-party representatives must not, directly or indirectly:

• Offer, promise, authorize, or give anything of value to any Government Official, private sector entity, or any individual to improperly influence business decisions or gain an unfair advantage.
• Solicit, accept, or receive any form of bribe or inducement in exchange for favorable treatment.
• Engage in or facilitate corrupt practices, including kickbacks, fraud, or misrepresentation.

3. Business Ethics and Integrity
S4D expects all employees and business partners to adhere to the highest ethical standards in all business dealings. This includes:

• Compliance with all applicable local and international laws and regulations.
• Fair and transparent business practices in procurement, contracting, and service delivery.
• Avoiding conflicts of interest, including personal or financial interests that may impair objectivity in decision-making.
• Reporting any suspicious or unethical behavior through appropriate internal channels.

4. Payment of Commissions
S4D does not authorize or permit the payment of commissions, facilitation payments, or success fees to intermediaries, agents, or third parties unless:

• Such payments are for legitimate services rendered.
• The transaction is fully documented, approved by senior management, and complies with all legal and regulatory requirements.
• The recipient undergoes due diligence and is subject to contractual compliance obligations.

5. Gifts and Entertainment
The exchange of business courtesies, such as gifts and entertainment, must be reasonable, transparent, and not intended to influence business decisions improperly. The following guidelines apply:

• Gifts or entertainment must not exceed a nominal value and should align with customary business practices.
• No cash or cash equivalents (e.g., gift cards, loans) may be given or accepted.
• Any gifts or hospitality involving Government Officials must be pre-approved by S4D’s Compliance Officer.
• Employees must document and report all gifts and entertainment exceeding a specified threshold to ensure transparency and accountability.

6. Interaction with Government Officials
Employees and representatives of S4D must adhere to strict ethical standards when dealing with Government Officials:

• No payments, gifts, or favors may be offered to Government Officials in exchange for business advantages.
• Any engagement with Government Officials must be conducted transparently and in compliance with applicable laws.
• Employees must seek prior approval before entering into agreements, donations, or sponsorships involving Government entities.

7. Compliance Monitoring and Reporting

• S4D will conduct periodic training and awareness programs to reinforce compliance obligations.
• Employees must promptly report any suspected violations of this policy to the Compliance Officer or through the confidential reporting mechanism.
• S4D prohibits retaliation against employees who report compliance concerns in good faith.
• Violations of this policy may result in disciplinary action, including termination of employment or business relationships.

S4D is committed to fostering a culture of ethical conduct and compliance. Adherence to this policy ensures that S4D upholds its values, maintains trust with stakeholders, and complies with all applicable legal and regulatory requirements.