Anti-Bribery and Anti-Corruption Policy

Organization: Igzibo Engineering Solutions, Inc.
Version: 1.1
Status: Living policy
Effective Date: September 16, 2026
Owner: Igzibo Engineering Solutions, Inc.
Review Cycle: At least annually and after material legal, regulatory, geographic, ownership, or business changes.

1. Purpose

This policy establishes Igzibo Engineering Solutions, Inc.'s prohibition against bribery, corruption, kickbacks, and other improper payments or benefits.

It is intended to support lawful and ethical business relationships with clients, candidates, employees, contractors, recruiters, vendors, government personnel, and other business partners.

2. Scope

This policy applies to:

• Employees.
• Contractors.
• Consultants.
• Recruiters and staffing partners acting for Igzibo.
• Officers and directors where applicable.
• Agents and representatives.
• Vendors and intermediaries where contractually applicable.
• Other persons acting on behalf of Igzibo.

Definitions

Bribery: Offering, promising, giving, requesting, or accepting something of value to improperly influence a decision or action.

Corruption: Abuse of entrusted authority or position for improper personal or organizational benefit.

Facilitation Payment: A payment intended to influence routine governmental action. Such payments may be unlawful and are prohibited by this policy unless qualified legal counsel determines otherwise under applicable law.

FCPA (Foreign Corrupt Practices Act): A U.S. federal law containing anti-bribery and accounting provisions applicable in specified circumstances.

FEPA (Foreign Extortion Prevention Act): A U.S. federal law addressing certain demands by foreign officials for bribes.

Igzibo: Igzibo Engineering Solutions, Inc.

Improper Payment: Money, benefit, gift, favor, commission, fee, or other thing of value provided or accepted for an unauthorized or improper purpose.

Government Official: A person who qualifies as a government official under applicable law. The term can include persons beyond elected officials.

4. Zero-Tolerance Rule

Igzibo prohibits bribery and other improper payments.

No employee, contractor, recruiter, vendor, or representative may offer, promise, authorize, provide, request, or accept an improper benefit in connection with Igzibo business.

Business pressure, revenue targets, client demands, project deadlines, or recruiting objectives do not justify violating this policy.

5. Things of Value

Improper benefits may include:

• Cash.
• Gifts.
• Meals.
• Travel.
• Entertainment.
• Employment opportunities.
• Internships.
• Discounts.
• Loans.
• Commissions.
• Referral fees.
• Donations.
• Favors.
• Services.
• Other benefits.

The absence of a cash payment does not make conduct acceptable.

6. Government Officials

Personnel must use particular caution when interacting with government officials.

No benefit may be provided to improperly influence a government decision, obtain an advantage, secure business, avoid an obligation, or otherwise obtain an improper benefit.

When uncertainty exists, personnel must escalate the matter before providing the benefit.

7. Recruiting and Referral Fees

Recruiter commissions and referral fees may be legitimate business expenses when properly authorized, documented, and consistent with applicable agreements.

Such payments must not:

• Conceal a bribe.
• Be paid to improperly influence a client decision.
• Be routed through an undisclosed intermediary for an improper purpose.
• Be falsely recorded.
• Be structured to conceal the identity or purpose of the recipient.

International recruiter and staffing relationships should receive appropriate due diligence.

8. Gifts and Hospitality

Gifts and hospitality must have a legitimate business purpose and must not be intended to improperly influence a decision.

Personnel must consider:

• Recipient.
• Value.
• Frequency.
• Timing.
• Business purpose.
• Applicable law.
• Client or employer policies.
• Whether the benefit could reasonably appear improper.

Extra caution is required during procurement, contract negotiations, audits, government interactions, and competitive selection processes.

9. Third-Party Intermediaries

Igzibo must not use a third party to perform conduct that Igzibo personnel could not properly perform directly.

Before engaging higher-risk intermediaries, Igzibo should consider:

• Identity and ownership.
• Business purpose.
• Qualifications.
• Reputation.
• Geographic risk.
• Compensation.
• Services provided.
• Government relationships.
• Contractual terms.
• Red flags.

Payments must correspond to legitimate services and be supported by appropriate records.

10. Books and Records

Igzibo business records must accurately describe transactions.

Personnel must not create false descriptions, conceal payments, create fictitious services, or use misleading expense categories to disguise a payment.

Supporting documentation should be retained according to applicable record-retention requirements.

11. Due Diligence

Risk-based due diligence should be performed for third parties whose roles or circumstances create elevated corruption risk.

Examples may include:

• Government-facing representatives.
• International agents.
• Recruiters operating in higher-risk jurisdictions.
• Consultants with unusual compensation arrangements.
• Intermediaries selected because of government relationships.

12. Conflicts of Interest

Potential conflicts involving vendors, recruiters, clients, or representatives must be disclosed according to the Conflict of Interest Policy.

Personal relationships must not be concealed when they create a material risk of improper influence.

13. Political and Charitable Contributions

Igzibo resources must not be used for political or charitable contributions in a manner that violates law, client requirements, or this policy.

No contribution may be used as a disguised payment to obtain an improper business advantage.

14. Reporting

Personnel must promptly report suspected:

• Bribery.
• Kickbacks.
• Improper payments.
• Suspicious commissions.
• Unusual requests for cash or benefits.
• Requests to falsify records.
• Third-party corruption concerns.
• Other conduct potentially violating this policy.

Reports should use the reporting channel designated by Igzibo.

15. Non-Retaliation

Igzibo prohibits retaliation for making a good-faith report or participating in an authorized investigation, subject to applicable law.

16. Investigations

Igzibo may investigate suspected violations.

Personnel must preserve relevant records and cooperate with authorized investigations.

No person may destroy, alter, or conceal relevant records to avoid review.

17. Training

Personnel whose duties create elevated corruption risk should receive appropriate anti-bribery and anti-corruption training.

Training should be proportionate to the person's role and geographic or business exposure.

18. Enforcement

Violations may result in corrective action, removal from an engagement, contractual remedies, termination of employment or business relationships where applicable, or legal action.

19. Exceptions

Exceptions require documented review and authorization from an appropriate Igzibo authority.

No exception may authorize conduct prohibited by law.

20. References and Research Basis

This policy was informed by:

• U.S. Department of Justice and U.S. Securities and Exchange Commission, FCPA Resource Guide, Second Edition
• U.S. Department of Justice, FCPA Resource Guide Addendum addressing the Foreign Extortion Prevention Act

The application of anti-corruption laws depends on specific facts and jurisdictions. This policy does not replace legal advice.

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