Anti-Bribery Policy

1. Purpose

Kozen Marine Survey Company is committed to conducting business with the highest standards of integrity and professionalism. This Anti-Bribery Policy is established to prevent, detect, and respond to bribery and corruption in any form within our operations, in compliance with all applicable laws and regulations.

2. Scope

This policy applies to all employees, directors, consultants, agents, contractors, and any third parties acting on behalf of Kozen Marine Survey Company, regardless of their location.

3. Definition of Bribery

Bribery involves offering, giving, receiving, or soliciting something of value (such as money, gifts, or favors) to influence a decision or gain an unfair advantage in business dealings.

4. Policy Statement

1. Zero Tolerance: Kozen Marine Survey Company strictly prohibits bribery or corruption in any form.
2. No Facilitation Payments: Small, unofficial payments made to expedite routine government actions (facilitation payments) are not permitted.
3. Gifts and Hospitality: Gifts or hospitality must never be offered or received with the intention of influencing business decisions. They must always be reasonable, proportionate, and transparent.
4. Third Parties: We expect all third parties acting on our behalf to comply with this policy. Appropriate due diligence must be conducted prior to engaging with third parties.
5. Record-Keeping: All transactions must be accurately recorded in our books and records. No accounts may be kept “off the books” to facilitate or conceal improper payments.

5. Reporting Violations

All employees and associated parties have a duty to report any suspected violations of this policy. Reports can be made confidentially to the management or through designated reporting channels. Retaliation against whistleblowers is strictly prohibited.

6. Consequences of Non-Compliance

Breaches of this policy may result in disciplinary action, including termination of employment or contract, and may also lead to criminal prosecution.

7. Review and Updates

This policy will be reviewed periodically and updated as necessary to reflect changes in laws or company operations.