Anti-Corruption Policy for K2 Ultimate Incentives

 1. Purpose: Our organization is committed to conducting its business operations with integrity and in  compliance with all applicable laws and regulations. Bribery and corruption in any form  are unacceptable and undermine trust, fairness, and transparency. This Anti-Corruption  Policy outlines our commitment to preventing bribery and corruption within our  organization and among our business partners.  

 2. Policy: 

  a. Prohibition of Bribery: No employee shall offer, give, receive, or solicit any bribe or  improper payment, whether in cash or in kind, to or from any individual, including but not  limited to government officials, customers, suppliers, or any other third parties.  

 b. Facilitation Payments: Facilitation payments, often referred to as "grease payments,"  are also prohibited. These are payments made to expedite routine government actions,  such as obtaining permits or licenses, to which the payer is entitled.   

c. Gifts and Hospitality: Gifts, entertainment, or hospitality may be offered or accepted  only if they are modest, legal, and ethical, and do not create a conflict of interest or the  appearance of impropriety.   

d. Record-Keeping: Accurate and transparent records of all transactions and  expenditures must be maintained in accordance with applicable laws and regulations. 

 e. Reporting: Any employee who becomes aware of or suspects any violation of this  policy must report it immediately to their supervisor, the Compliance Officer, or through  the designated reporting channels outlined in the Whistleblower Policy.   

 3.. Compliance: All employees are required to read, understand, and comply with this Anti Corruption Policy. Violations of this policy may result in disciplinary action, up to and  including termination of employment, and may also lead to civil or criminal penalties for  individuals and the organization.

 4. Review and Updates: This policy shall be reviewed periodically to ensure its effectiveness  and compliance with applicable laws and regulations. Any updates or revisions to this policy shall be communicated to all employees.