PURPOSE

PIKOHANA‘s commitment to doing business with integrity means avoiding corruption in any form, including bribery, and complying with the anti-corruption and ethical laws.

Our Anti-Corruption and Business Ethics Policies provide guidance on how to conduct business in a fair, ethical and legal manner. These policies encompass our dealings with both the government and private parties. All our associates are required to read, understand, and follow the precepts of these policies, which include anti-corruption expectations for all employees. It is vital that we not only understand and appreciate the importance of these policies, but comply with them in our daily work.

Procedures are in place to ensure that the policies are adhered to when dealing with government officials and private parties. Below is a brief on these policy statements and procedures.

RESPONSIBILITIES

All employees of are expected to comply with the provisions of this policy and have the responsibility of reporting non-compliant practices.

‘s Managing Director or his appointee is responsible for:

  • Overseeing the policy and ensuring compliance.
  • Managing the policy on a day-to-day basis.
  • Making sure that any questions or clarifications about the implementation of this policy and its contents are addressed in a timely manner.

DEFINITIONS

Who is a “Government Official”?

A “Government Official” refers to (1) an official or an employee of; and (2) any person acting in official capacity for or on behalf of:

  • any government, governmental agency or instrumentality, or any public international organization;
  • any company that is controlled by a government or governmental agency (notwithstanding that the company may be publicly listed); and
  • any political party, party official or political candidate.

POLICY STATEMENTS

Pre-Clearance Requirements

1. Meals, entertainment, or gifts for a Government Official or a Private Party may be permissible ONLY if:

  • appropriate in light of existing law: if local laws do not permit it, we don’t offer or give regardless of value.
  • reasonable
  • not excessive in nature or frequency
  • not offered or given to influence an official action/decision or secure an improper advantage
  • not offered or given to a spouse or family of the government official

2. PIKOHANA management and staff must obtain a pre-clearance from PIKOHANA leadership before offering or giving any meals, entertainment or gifts even if this is allowed by law.

3. A Pre-Clearance and Approval must also be obtained for any charitable contributions requested or proposed by a Government Official or Private Party.

4. Facilitation Payments or nominal payments made to expedite routine government actions, to a Government Official, is prohibited by PIKOHANA. In cases where employee health and safety is involved, the Facilitation Payment may be considered. A Pre-Clearance and Approval must be obtained.

Business Partners

PIKOHANA does not use private third parties, including any co‐investor, agent, consultant, joint venture partner, finder, or another intermediary (collectively, “Business Partners”) to do something indirectly that it would not otherwise do directly. Business Partners that present the most corruption‐related risk are those which will have interaction with Government Officials and state‐controlled entities. In order to mitigate this risk, appropriate steps must be taken, as described below.

Client or Government Official Referrals

PIKOHANA hires employees, based on the merits of the candidate vis a vis other candidates. All candidates for a certain position undergo the usual hiring procedures. No candidate is hired based solely on recommendations or referrals by a Government Official, a client or any other Private Party.

Accurate Books and Records

PIKOHANA’s books and records accurately and fairly reflect, in reasonable detail, the transactions made which are covered by these policies. All of our employees do their part to ensure this.

VIOLATIONS OF THE POLICY AND APPLICABLE LAWS

  1. Violations of the Anti-corruption Policy and applicable laws may result in criminal, civil and regulatory penalties against PIKOHANA and individual employees. This could negatively impact PIKOHANA’s ability to conduct business in particular jurisdictions.
  2. Failure to comply with this Policy may also result in disciplinary action, including termination of employment. Any investigation and disciplinary actions shall be in accordance with the Personnel Policy on Disciplinary Actions.

POLICY REVIEW

  1. This policy is reviewed every 12 months in compliance with the Quality Management Policy.
  2. Associated procedures and guidelines are also reviewed with the policy.