ABAC policy

Bribery is never acceptable. As we strive to further our business interests and outperform our competitors, we will do so honestly, fairly, openly, and with integrity. We have a zero-tolerance policy towards bribery.

In keeping with the GRD Boutique sarl Code of Conduct and our commitment to obey all laws and regulations that apply to our business, we will support and abide by all relevant laws and regulations regarding anti-bribery and anti-corruption.

Our anti-corruption and anti-bribery policy is driven mainly by the following risk-based principles:

• We do not permit promising, making, approving, or accepting bribes, kickbacks or illegal payments, whether directly or through a third party, to obtain an improper advantage. Even the appearance of paying bribes through other means (such as lavish trips, hospitality, meals, entertainment or gifts; and improper political or charitable contributions) must be avoided. Likewise, we prohibit making facilitating payments.

• We will maintain complete and accurate books and records, and internal controls to ensure a complete, accurate, and sufficiently detailed accounting of all business transactions, expenditures, and use of assets. This is to prevent the concealment of bribes through unrecorded “off-books” transactions or fake recordkeeping.

•Customary gifts, meals, entertainment, travel, promotional giveaways, sponsorships, remuneration, or other things of value intended for public or government officials or for commercial persons or entities, if permitted and pre-approved by us, must be of reasonable value and justifiable with no intention to obtain improper advantage.

• Charitable donations must be to a bona fide charity and for bona fide and measurable charitable programs/purposes. These must also be pre-approved by us.

• The use of sub brokers or other third parties must be disclosed and must be for bona fide and legitimate services, with reasonable and customary charges based on the services being provided.

• We will maintain anti-corruption due diligence procedures for sub-brokers or other third parties having business relationships with or acting on behalf of the company.

• We will maintain training procedures to assure that employees and representatives are aware of, understand, and abide by these requirements.

• We will maintain procedures to test compliance with these requirements and to assure an appropriate level of review for potentially high-risk transactions, including transactions involving public or government officials or institutions, and transactions with private persons or companies where there is a potentially high risk for bribery or corruption.

• We will maintain reporting mechanisms so that those who suspect, know or are concerned that a corrupt act of some kind is being considered or carried out – either within GRD Boutique sarl, by any of our business partners, or by any of our competitors – can report the matter to us. One of these reporting mechanisms is sending email to george@grdboutique.com, which allows for confidential and anonymous reporting, or contact GRD Boutique sarl’s accountants/ auditors office at +357 25 581113

• Complaints : Complaints of any sort could be sent to george@grdboutique.com or by contacting GRD Boutique sarl’s accountants/ auditors office at +357 25 581113