IND /HR/P/01/R01 Date: 2/08/2016

Bribery and Corruption Policy

Introduction

Induspects reputation is that of an ethical and honest business. We are committed to acting without the use of bribery

or corruption in a very competitive marketplace. Bribery and corruption are morally and legally wrong and any such acts

expose the Company and the persons involved to criminal sanctions and reputational damage.

A zero tolerance approach will apply to any act of bribery and corruption by our employees. Any breach will be

considered misconduct and will result in disciplinary action which may include termination of employment.

What are bribery and corruption?

Bribery is the offering or accepting of some advantage in return for doing something which is illegal or unethical or which

would result in a breach of trust. Bribery involves an improper attempt to influence how a person performs a duty. It

can take many forms. It can be done to influence a person to not do that persons duty. It can be done to influence the

person to do the duty in a way that benefits the person offering the bribe. It can be done to influence future favourable

treatment. There is always something sought in return for offering or accepting the bribe. What is sought in return does

not have to be immediate or even of monetary value.

Corruption is behaviour which is dishonest but not necessarily illegal. Employees have obligations of trust and faithful

service towards Induspect. An Induspect employee who uses or abuses his or her position of trust to benefit himself or

another is engaging in corruption. It does not have to disadvantage Induspect for it to be corruption. The offending

conduct is the breach of trust.

When is bribery and corruption likely to happen?
Bribery is most likely to occur where the person who is offered the bribe is in a position to make a decision about
whether to do business with Induspect. It might involve how much business Induspect will obtain or what prices will be
paid to Induspect for its services. It can occur where the doing or not doing of an act (by the person receiving the bribe)
can affect Induspects ability to carry out an existing contract or affect the costs of performing that contract. It can also
involve a government or other official who has the ability to interfere with for good or bad Induspects business
activities.
Corruption is most likely to occur where the Induspect employee has a discretionary choice about making expenditures
of Induspect funds, where making one choice rather than another will benefit the employee or some person of the
employees choosing, even if it does not disadvantage Induspect.
What conduct by Induspect employees is not acceptable?
Induspect employees must not in any circumstances and whether directly or indirectly:
Offer money, gifts or any other financial advantage to anyone in order to obtain business or obtain particular
business outcomes for Induspect.
Accept money, gifts or any other financial advantage from anyone in order to influence a business decision
Induspect might make.
Offer or accept sexual, political or other favours in order to have a person behave in a particular way in respect of
Induspect.
Act in a way, without the knowledge of Induspect, which personally benefits the employee performing the act.
What conduct by Induspect employees is acceptable?
Bribery
Induspect employees will have social relations with persons capable of making decisions that affect Induspect. These
social relations may involve providing or accepting hospitality or exchange of gifts at festive seasons. Having an
occasional meal or a drink with an Induspect client employee is not corruption but it could be. Nor is an exchange of
for example small low value Christmas presents but it could be.
The test is: What is the intent? The intent will be judged objectively. If it would look bad if published in the media
it is not acceptable. If it would look bad if the roles were reversed - the person accepting the bribe was the person
offering it - it is not acceptable. If the Induspect employee has any doubt about the propriety of engaging in such social
conduct with anyone, it is not acceptable.
Corruption:
If the conduct is known by and approved by Induspect it will not be regarded as corruption.