Unitel Group

Anti-Bribery Policy and Procedures

The policy defines the ethical standards for Group operations and focuses on preventing bribery risks while mitigating potential exposures.

Influencing the authority or decisions of officials or executives
Persuading them to act or refrain from acting in a manner inconsistent with their duties
Inducing misuse of their position for influence
Securing new business opportunities, retaining business, or gaining unfair advantage;
Requesting, demanding, or accepting anything of value (e.g., gifts, cash, discounts, or incentives) from anyone conducting business or intending to work with the Group in connection with performing their duties or declining to do so.

General Principle

Employees and third parties of the Group are prohibited from offering, promising, or giving anything of value, directly or indirectly, to government officials or company executives for the purpose of:

Anti-Bribery Compliance Program

The Compliance Unit oversees high-risk activities, and employees must notify and obtain approval from the Compliance Unit in the following situations:

Gifts

Gifts may be exchanged in the course of business relationships with clients, provided they are modest, non-luxurious, associated with holidays or celebrations, and not intended to influence decisions.

Business Meetings

Meetings aimed at promoting the Group's objectives or strengthening partner relationships are allowed. Such meetings should be modest, infrequent, and avoid creating any improper impression.

Charitable Donation

The Group may make donations using internal resources, products, or services under corporate social responsibility programs, without attempting to influence any individual's decisions.

Political Contributions and Activities

The Group may support political parties or candidates in accordance with applicable laws and this policy, ensuring all contributions are accurately recorded in the Group's relevant registers. Employees may make political contributions and participate in political activities as private citizens, provided such participation does not create a perception of representing the Group. Employees should notify the Compliance Unit in advance for guidance if their role could create such risk.

Third Parties

Third parties acting on behalf of the Group are considered an integral part of its operations. Before engagement, third parties undergo due diligence and must comply with the Group's internal policies, ethical principles, and applicable laws at the same level as employees.