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LCM

Anti-Bribery and Corruption Policy

  1. Introduction

At LCM Services Ltd, we are committed to conducting our business ethically and with integrity. As part of this commitment, we have adopted this Anti-Bribery and Corruption Policy to ensure compliance with all applicable laws and regulations governing bribery and corruption.

  1. Scope

This policy applies to all employees, directors, contractors, consultants, agents, and any other parties associated with LCM Services Ltd (“the Company”).

  1. Prohibited Conduct

Bribery: Offering, giving, receiving, or soliciting any bribe, whether in the form of money, gifts, hospitality, loans, fees, rewards, or other advantages, to or from any person or company, in order to gain any commercial, contractual, regulatory, or personal advantage.

Corruption: Engaging in any corrupt activities, including but not limited to fraud, extortion, collusion, embezzlement, money laundering, or any other illegal practices.

  1. Compliance with Laws

All employees and representatives of LCM Services Ltd must comply with all applicable anti-bribery and corruption laws and regulations, including but not limited to the UK Bribery Act 2010 and any relevant laws in countries where the Company operates.

  1. Gifts, Hospitality, and Entertainment

Gifts: Giving or receiving gifts, entertainment, or hospitality must be reasonable, proportionate, and in compliance with company policies and applicable laws. Gifts should not be given or received with the intention to influence a business decision or gain an unfair advantage.

Hospitality: Offering or accepting hospitality, such as meals, travel, accommodations, or event tickets, must be for legitimate business purposes and should not create a conflict of interest or the appearance of impropriety.

  1. Conflicts of Interest

Employees and representatives of LCM Services Ltd must avoid situations where their personal interests conflict with the interests of the Company. Any actual or potential conflicts of interest must be disclosed promptly and managed appropriately.

  1. Reporting and Whistleblowing

Employees who suspect or become aware of any actual or potential violations of this policy must report their concerns immediately to their supervisor, manager, or the designated compliance officer. The Company prohibits retaliation against employees who report concerns in good faith.

  1. Consequences of Non-Compliance

Violations of this Anti-Bribery and Corruption Policy may result in disciplinary action, up to and including termination of employment or contractual relationship, and may also lead to civil or criminal penalties for individuals involved.

  1. Training and Awareness

LCM Services Ltd will provide regular training and awareness programs to ensure that all employees and representatives understand their obligations under this policy and are equipped to recognize and address bribery and corruption risks.

  1. Review and Revision

This policy will be reviewed periodically and updated as necessary to reflect changes in laws, regulations, or business practices.

Conclusion

LCM Services Ltd is committed to maintaining the highest standards of integrity and ethical conduct in all aspects of its business operations. Compliance with this Anti-Bribery and Corruption Policy is essential to uphold our reputation and build trust with our stakeholders.