Anti-Corruption Policy

XTRM Group, as a Service Provider company, is strongly committed to the highest standards of ethics and integrity. The purpose of this Anti-Corruption Policy is to prevent, detect and sanction any act of corruption or fraud within the organization and in its relations with partners, customers, suppliers and other stakeholders.

Scope

This policy applies to:

• All employees, officers, Managers, Associates, and Partners of XTRM Group
• All consultants, contractors, suppliers and other business partners acting on behalf of XTRM Group
• Any other person or entity having business dealings with XTRM Group

What is Corruption?

Bribery is defined as the act of offering, promising, giving, receiving or soliciting an undue advantage of any kind, with the aim of improperly influencing an action or decision. This includes:

• Bribe: any amount of money, gift, favor or service offered or received for the purpose of influencing a business decision.
• Influence peddling: the use of a position or influence to obtain an undue advantage.
• Embezzlement: the illegal appropriation of the company’s financial or material resources.
• Conflicts of interest: any situation where an employee or representative of XTRM Group has personal interests that may affect his or her objectivity in the performance of his or her responsibilities.

Principles and Commitments

XTRM Group is committed to:

• Zero tolerance for any form of corruption, whether active or passive, direct or indirect.
• Compliance with applicable anti-corruption laws, including those in force in the Democratic Republic of Congo and international conventions.
• Obligation to report: Any employee or partner who suspects an act of corruption must immediately report it to the competent internal authorities.
• Protection of whistleblowers: Retaliation will not be taken against a person who denounces an act of corruption in good faith.
• Regular checks and audits to ensure compliance with anti-corruption rules.

Gifts & Invitations

XTRM Group strictly prohibits:

• The offer or acceptance of gifts, invitations or benefits that may influence a business decision.
• Facilitation payments intended to expedite an administrative or commercial procedure.

Any exceptions must be approved by the Operations Management and the Office of the Managing Partner and documented in a transparent manner.

Awareness and Training

XTRM Group implements regular training programs to inform its employees and partners about the risks of corruption and how to prevent them.

Sanctions

Failure to comply with this policy may result in:

• Disciplinary sanctions up to and including dismissal for employees.
• Immediate termination of Agreements for the business partners involved.
• Legal actions in the event of a violation of the law.