POLICY STATEMENT

K.U.S Group will maintain a zero-tolerance approach to fraud, bribery, corruption and conflict of Interest within the organization, from K.U.S Holdings up to its subsidiaries and affiliates.
This Policy applies to all directors, officers, employees (including temporary or contract staff), and to all third-party individuals and organizations acting on our behalf or with whom we do business (including suppliers, subcontractors, agents and joint-venture partners).

Definitions:

• Fraud- any intentional act or omission designed to deceive others, resulting in the misappropriation of assets, manipulation of records, or unlawful gain for personal or organizational advantage.
• Conflict of Interest– arises when a person’s personal, financial, or other interests interfere — or could appear to interfere — with their professional responsibilities and the best interests of the Company
• Bribery– is an illegal and unethical act involving the offering, giving, receiving, or soliciting of something of value (often money, goods, services, favours, or advantages) to influence the actions, decisions, or behaviour of an individual or organisation in a way that is dishonest, unfair, or against the best interests of others. It typically involves in exchange of something of value in return for an action or decision that provides an unfair advantage or favours one party or the others. Bribery involves the giver and the receiver in the improper performance of a company or official responsibility.
• Corruption refers to the abuse of power, authority, or position for personal gain or to achieve fair advantage. It involves dishonest or unethical behaviour and can manifest in various forms including bribery, embezzlement, fraud, nepotism, extortion, and misuse of public resources.

The following are the Prohibited Conduct (the list is limited, and all other activities related, similar or violates the internal policies of K.U.S Group shall be included and will be investigated accordingly):

• Bribery and Corruption
  • Employees are strictly prohibited from offering, giving, receiving, or soliciting bribes, kickbacks, or any other form of corrupt inducement, whether cash or in-kind, to or from any person or entity, whether in the public or private sector.
  • This includes bribes to government officials, suppliers, customers, competitors and any third parties.
  • Likewise, suppliers, agents, customers and all third parties shall not bribe or attempt to bribe any K.U.S employees and/or directors and officers.
• Facilitation Payments
  • Facilitation payments are small payments or gifts made to expedite routine governmental actions.
  • U.S prohibits facilitation payments in all circumstances.
• Gifts and Hospitality
  • Employees are strictly prohibited from directly or indirectly seeking and accepting cash, commission, credit, gift, gratuity and items of value or compensation of any kind from supplier and client.
  • The mentioned must be reported and the items received must be surrendered to the Appointed Officer immediately

• Fraudulent Actions
  • Intentional falsification or alteration of documents (invoices, purchase orders, shipping/delivery records, time-sheets, expense claims) for personal gain or to mislead the company.
  • Misappropriation or theft of company assets (equipment, materials, inventory, cash, or proprietary information).
  • Concealment or omission of material facts; misrepresentation in reports or internal records; manipulation of data or financial records .
  • Any attempt to avoid or circumvent established internal controls, or to mislead auditors or regulators.
  • Other fraudulent means or activities
• Conflict of interest
  • Actions or interest that are in conflict tin the business of any K.U.S company
  • Activities entered by Shareholders, Directors and or employees that will compromise the business and operation of any K.U.S company.
  • Other acts that may be in conflict with any policies and regulations of K.U.S Group.

 Reporting and Investigation
We encourage all individuals to report any suspicion or evidence of fraud. Reports can be made to the designated email addresses:

Appointed Officer	Email Address
Whistleblowing Appointed Officer	mag@kusgrp.com
Incident Reporting Committee	irc@kusgrp.com
Legal Department	legal@kusgrp.com

***Only reports regarding fraud, bribery, corruption and conflict interest will be entertained. Public should avoid sending quotation or complaints about products in the above-stated email address. For other concerns please contact the specific sales agent or procurement agent you are dealing with.

Once a report is received, we will promptly and impartially investigate the matter, preserving evidence, preventing escalation, maintaining confidentiality, and ensuring fairness to all parties involved. Fraudulent acts, once substantiated, will result in disciplinary action up to and including termination of employment, and may lead to civil or criminal proceedings. We will also seek recovery of losses and cooperate fully with law-enforcement and regulatory authorities where applicable.

Consequences of non-compliance
Any individual (employee, contractor, supplier) who fails to comply with this Policy or engaging in fraudulent conduct will lead to appropriate disciplinary measures, including termination and possible legal action. Any K.U.S Company may terminate contracts, recover losses, and report the matter to regulators or law-enforcement authorities if required.

Review and updates
This Policy Statement will be reviewed regularly (at least annually) and whenever there are significant changes to our business operations, risk environment, regulatory obligations or supply-chain profile. Updates will be communicated to all stakeholders and training refreshed accordingly.

Declaration
By working with any K.U.S Group you are agreeing to uphold this Policy, act with honesty, integrity and transparency in all dealings, and contribute to our shared culture of ethical business conduct.