Anti-Bribery and Anti-Corruption Policy

Innovative Minds Consulting Limited (referred to as iMinds for short or the Company) management is continuously making efforts to enhance corporate governance, risk management and internal controls (GRC) to ensure that business objectives are achieved, and the growth opportunities can be materialized. Developing and implementing this policy is a milestone towards that goal. This policy has been developed in line with iMinds business goals.

Therefore, all employees and business associates of the Company (iMinds) are instructed to follow this policy for aligning their conduct during the engagement with iMinds. This policy is approved by the Board of Directors of the Company.

1. Policy Statement

Innovative Minds Consulting Limited is committed to conducting all its business activities with the highest standards of integrity, transparency, and ethical conduct. The Company adopts a zero-tolerance approach to bribery and corruption in any form.

2. Scope of Application

This Policy applies to all employees, directors, officers, consultants, agents, contractors, clients, suppliers, and business partners of the Company. It applies to all business dealings in Bangladesh and internationally.

3. Definition of Bribery and Corruption

Bribery is offering, promising, giving, requesting, or accepting any financial or other advantage to improperly influence a decision or action. Corruption includes bribery, facilitation payments, kickbacks, extortion, fraud, or abuse of entrusted power for private gain.

4. Prohibited Conduct

The following actions are strictly prohibited: - Offering or accepting bribes or kickbacks - Improper gifts or hospitality intended to influence decisions - Facilitation payments - Bribery of public or private individuals - Using third parties to conduct bribery - Concealing or misrepresenting transactions.

5. Gifts and Hospitality

Reasonable and proportionate gifts or hospitality may be permitted if lawful, transparent, modest in value, and properly recorded. Cash or cash-equivalent gifts are strictly prohibited.

6. Facilitation Payments

The Company does not permit facilitation payments under any circumstances.

7. Dealings with Public Officials

All dealings with public officials must be lawful, transparent, and approved by senior management where required.

8. Third-Party Relationships

All third parties acting on behalf of the Company are expected to comply with this Policy. The Company reserves the right to terminate relationships in case of violations.

9. Record-Keeping and Financial Controls

All transactions must be accurately recorded and supported by proper documentation. False or misleading records are prohibited.

10. Reporting and Whistleblowing

Any suspected bribery or corruption should be reported to senior management. Reports may be made confidentially.

11. Protection Against Retaliation

The Company prohibits retaliation against individuals who report concerns in good faith.

12. Breach of Policy

Violations may result in disciplinary action, termination of contracts, or legal action.

13. Training and Awareness

The Company will ensure appropriate awareness and training on this Policy.

14. Policy Review

This Policy will be reviewed periodically to ensure effectiveness and compliance.