Anti-Bribery & Anti-Corruption Policy

ANTI-BRIBERY & ANTI-CORRUPTION POLICY

1. Hadō is committed to running our business operations on a foundation of Integrity, Transparency and Honesty. Our Company will devise and improve our processes continuously to prevent direct or indirect bribery, in order to safeguard and uphold our values.
2. Hadō adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Our Company and employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices, nor facilitate any such practices.
3. Hadō does not allow our employees to solicit or accept any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favor or advantage of any description whatsoever, from any organization, firm or individual or government officials with whom they deal with in the course of the employment. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.
4. Hadō does not allow our employees to promise or offer or to give any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment, including government officials. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.
5. Hadō has clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to.
6. Hadō has an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.
7. If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions, including immediate dismissal of employment and/or referral to relevant law enforcement authorities.
8. Hadō will also strive to ensure that our business partners share our zero tolerance policy against corruption and bribery. Hadō will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.
9. Procurements by Hadō are conducted in a fair and transparent manner.