Anti-Corruption Policy

Introduction

ISS IMPLANT SUPPORT SERVICES (PTY) LTD is committed to conducting its business with integrity, transparency, and in compliance with all applicable laws and regulations. As part of this commitment, we have established this Anti-Corruption Policy to outline our zero-tolerance approach towards corruption in any form.

Scope

This policy applies to all employees, officers, directors, contractors, consultants, and agents representing ISS, regardless of their position or level within the organization.

Definitions

– **Corruption**: Any act of bribery, extortion, kickbacks, fraud, embezzlement, or other unlawful or unethical conduct intended to gain undue advantage or influence improperly.

– **Bribery**: Offering, giving, receiving, or soliciting anything of value to influence the actions or decisions of individuals in a position of trust or authority.

Compliance with Laws and Regulations

All employees are expected to comply with the anti-corruption laws and regulations of the countries and jurisdictions in which ISS operates.

Prohibited Conduct

– Offering, promising, giving, or accepting bribes or kickbacks, whether directly or indirectly, to or from any individual, including government officials, business partners, or third parties.

– Engaging in any form of extortion, fraud, embezzlement, money laundering, or other corrupt practices.

– Facilitating payments, except where permitted by applicable law and properly documented.

– Providing or receiving gifts, hospitality, or entertainment that could be perceived as intended to improperly influence business decisions or gain preferential treatment.

– Engaging in any transaction or business arrangement that lacks transparency or violates ethical standards.

Gifts, Hospitality, and Entertainment

All gifts, hospitality, and entertainment provided or received in the course of business dealings must be reasonable, proportionate, and in compliance with applicable laws and company policies. Employees must obtain prior approval for gifts or entertainment exceeding specified thresholds.

Due Diligence and Third-Party Relationships

Before entering into any business relationship or engaging third-party representatives, employees must conduct appropriate due diligence to assess the integrity, reputation, and compliance record of potential partners, agents, suppliers, and contractors.

Reporting and Whistleblowing

Employees are encouraged to report any suspected violations of this policy or concerns regarding corrupt conduct promptly. Reports can be made to info@implant.co.za through the company’s whistleblowing channels, which guarantee confidentiality and protection against retaliation.

Training and Awareness

ISS will provide regular training and awareness programs to educate employees about their obligations under this policy, including the identification and prevention of corrupt practices.

Enforcement and Consequences

Violations of this policy will result in disciplinary action, up to and including termination of employment, and may also lead to legal proceedings and civil penalties. ISS reserves the right to take appropriate action against third parties found to be involved in corrupt activities.

Review and Revision

This policy will be periodically reviewed and updated to ensure its effectiveness and alignment with evolving legal and regulatory requirements.

Conclusion

By adhering to this Anti-Corruption Policy, we demonstrate our commitment to upholding the highest standards of integrity, accountability, and ethical conduct in all aspects of our business operations.