6. Anti-Corruption and Bribery Policy

SCOPE

This Policy applies to Aluminij Industries (hereinafter “Aluminij” or “we”) and all employees, and officers.

In addition, the Aluminij expects its agents, consultants, representatives, suppliers, vendors, contractors, advisors, business partners and any other person that performs services for or on behalf of the Company to comply with the principles contained in this Policy.

It is intended to minimize Aluminij’s risks related to bribery and corruption and to emphasize responsibilities under both the relevant anti-corruption laws and our policies. It also provides guidance on identifying potential risks, dealing with challenging situations and reporting when those situations violate or may lead to a violation of this Policy and Anti-Corruption Laws.

Corruption and bribery are illegal and unethical, and any violation of relevant anti-corruption laws can lead to severe civil and criminal penalties and reputational harm to Aluminij.

Aluminij has zero tolerance for corrupt activities of any kind. Bribes or other improper or unauthorized payments, or acts that create the appearance of promising, offering, giving, or authorizing such payments, are prohibited by this Policy.

Offering, promising, and authorizing the giving of money, or anything else of value, to a government official in order to secure an improper advantage is strictly prohibited.

The Company’s prohibition on bribery applies to all improper monetary or non-monetary, tangible or intangible bribes; payments of money; gifts or entertainment, discounts, loans and/or financing given on non-commercial terms, rebates or kickbacks in relation to services provided, including “facilitating” (or expediting) payments. Facilitating payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power, or water service, or loading or unloading of cargo.

INDICATORS FOR SUSPICION OF CORRUPT ACTIVITIES

The following is a list of activities that may indicate the possible existence of corrupt practices and should be kept in mind by all those subject to this Policy:

1. Unusually large commission payments,
2. Cash payments, or payments made without a paper trail or without compliance with normal internal controls,
3. Unusual bonuses for which there is little supporting documentation,
4. Payments to be made through third party countries or to offshore accounts,
5. Unexplained preferences for certain sub-contractors,
6. Invoices rendered or paid in excess of contractual amounts.

This list is not exhaustive.

GIFTS AND ENTERTAINMENT
This Policy does not prohibit normal and appropriate hospitality (given or received) to or from third parties.

Gifts and entertainment are commonly offered as gestures of gratitude or tokens of appreciation. We allow these tokens and gestures when they are reasonable, proportional, made in good faith and in compliance with our Code of Business Conduct and Ethics and this Policy.

All employees should consult with their superior for further guidance on giving or accepting gifts or forms of entertainment or hospitality.

It is not acceptable for any employee to:

1. give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or Aluminij will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
2. accept payment from a third party where it is known or suspected that it is offered or given with the expectation that the third party will improperly obtain a business advantage;
3. threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under this Policy; or
4. engage in any activity that might lead to a breach of this Policy.

POLICY BREACHES

It is the responsibility of all employees to ensure compliance with this Policy. Any employee who witnesses a breach of this policy is obliged to promptly contact Aluminij’s Compliance Officer.

Aluminij’s employees that violate these laws can face severe disciplinary, civil and criminal penalties.

POLICY REVIEW

This Policy shall be updated from time.