# Anti-Corruption Compliance Policy

### Purpose and Scope

The ICR Anti-Corruption Compliance Policy outlines ICR's unwavering commitment to legal and ethical conduct, strictly prohibiting bribery and corruption in all forms. This policy applies to all employees, associates, and partners associated with ICR.

### Adherence to Laws

ICR is dedicated to complying with all applicable anti-corruption laws and regulations.

### Prohibited Conduct

ICR strictly prohibits any form of bribery, kickbacks, or other corrupt activities, whether they are direct or indirect in nature.

### Gifts, Hospitality, and Travel

This policy establishes clear guidelines for giving and receiving gifts, hospitality, and travel expenses. It emphasizes that such activities must be reasonable, transparent, and not influence decision-making processes.

### Due Diligence

ICR places a strong emphasis on rigorous due diligence when engaging with partners, suppliers, and third parties to prevent any involvement in corrupt practices.

### Training and Awareness

Mandatory training on anti-corruption laws and policy adherence is provided to all employees, and relevant third parties are informed about the existence of this policy. This ensures that everyone associated with ICR clearly understands their responsibilities.

### Reporting and Whistleblower Protection

ICR encourages the reporting of any suspicious activities or policy violations. The organization is committed to providing protection to whistleblowers against any form of retaliation.

### Record Keeping

ICR maintains accurate and detailed financial records to ensure transparency and accountability in all its operations and is publicly available.

### Monitoring and Auditing

Regularly monitoring and auditing compliance with this policy are conducted to ensure its effectiveness.

### Policy Enforcement

ICR takes policy violations seriously and enforces strict disciplinary actions, which may include the termination of employment or contracts and potential legal consequences.

### Review and Update

ICR is committed to regularly reviewing and updating this policy to align with evolving legal requirements and best practices in the field of anti-corruption compliance.


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