Anti-Bribery, Anti-Corruption, and Anti-Slavery (“ABACAS”) Policy

Introduction

At Kestrel IDM, we are committed to maintaining the highest standards of integrity, transparency, and accountability. Kestrel IDM’s ABACAS policy framework outlines our stance against bribery, corruption, and slavery, and provides guidance for all employees, contractors, and associates.

Principles

1. Zero Tolerance: We have a zero-tolerance approach to bribery, corruption, and slavery. Such practices are contrary to our core values, and undermine an organisation’s credibility with its customers and suppliers.
2. Legal Compliance: We shall comply with all relevant anti-bribery, anti-corruption, and anti-slavery laws and regulations, including the UK Bribery Act 2010 and the Foreign Corrupt Practices Act (FCPA) in the U.S.
3. Scope: This policy applies to all individuals associated with Kestrel IDM, including employees, contractors, agents, intermediaries, and suppliers.

Key Provisions

Anti-Bribery and Corruption

• Offering, Promising, or Giving Bribes: We strictly prohibit offering, promising, or giving bribes to anyone, whether directly or indirectly.
• Requesting, Agreeing to Receive, or Accepting Bribes: We also prohibit requesting, agreeing to receive, or accepting bribes.
• Bribing Officials: Bribing foreign or local public officials to obtain or retain business is strictly prohibited.
• Strict Liability: Failure to prevent bribery by those acting on our behalf is an offense.

Anti-Slavery

• We condemn all forms of slavery, forced labor, and human trafficking.
• Supply Chain Due Diligence: We shall conduct due diligence on suppliers and partners to identify and mitigate slavery risks.
• Supplier Agreements: Our supplier agreements explicitly prohibit the use of forced labor or exploitative practices.
• Employee Awareness: We educate employees about recognizing and reporting slavery-related concerns.

Reporting and Compliance

• Employees must immediately report any suspected violations of our ABACAS policy framework.
• We shall provide awareness programs to educate employees about their responsibilities.
• Non-compliance by employees, contractors, agents, intermediaries, and suppliers will result in disciplinary action, and could result in termination.

Continuous Improvement

We shall regularly review and update this policy to adapt to changing legal requirements and best practices.