CORRUPTION

GARAUDE prohibits corruption in all business practices and transactions carried out by its employees and by agents acting on its behalf. For the purposes of this policy, corruption is defined as giving, offering or receiving an unfair advantage from or to: A civil servant or a public official; A candidate, party or political official; Any employee, director or manager of the private sector, or their agents or representatives.

All GARAUDE employees are protected against any sanction or negative consequence for having identified concerns related to suspicion of corruption, for refusing to participate in acts of corruption or for refusing to pay a facilitation payment when such payments are made. prohibited.

GARAUDE undertakes not to engage in or contribute to money laundering or the financing of terrorism and is fully compliant with the laws and regulations applicable to the fight against money laundering.

GARAUDE has implemented Know Your Counterparty (KYC) procedures for: Establish the identity of all counterparties; Check that the counterparties and, if applicable, check that the beneficial owners are not named on the relevant government lists for the persons or organizations involved in money laundering, fraud or involvement with prohibited organizations and / or those who finance the conflict; Maintain an understanding of the nature and legitimacy of businesses operated by counterparties and; monitor transactions for any unusual or suspicious activity.

Token of Appreciation

The acceptance or offering of gifts by employees and / or agents must be approved. Receiving and giving gifts is not practiced within day to day operations. Some allowance is made for giving or receiving small gifts such as during holiday seasons or other special occasions.