Anti-Corruption and Anti-Bribery Policy

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Golden
Cougar is committed to conduct our business in honest manner with high ethical standard. We conduct our activities in accordance with all applicable laws, rules and regulations.

Responsibility

• Anti-corruption and Anti-bribery policy apply to all members of Golden Cougar, working at all levels and grades (executive to basic employee of full-time, part-time, non-permanent and contractors) and wherever they located.
• Directors, Board of Directors, The Executive committee, The management Heads are responsible and accountable for
• Implementation of the policy
• Adequate and regular training to all members to understand and to get awareness the policy
• Monitoring the effectiveness of the policy
• Reporting the result of adherence to the policy

Corruption is the abuse of public private roles, resources and power for personal/ private benefit and non-official use.

Bribery is an inducement or offered reward or promise or illegal payment provided to gain any economic or non-economic benefits for the individual’s advantage.

Gift (a present with intention to get advantage or beneficial action) and Hospitality are needed to accept with the clear approval of business objective and relationship.

Donation is a gift typically for charitable purpose and benefits.

Facilitation Payment is unofficial payment to public official made to secure or expedite actions or favors.

Policy Statement

• We do not, and will not, pay or accept bribes or improper inducements to anyone for any purpose.
• We endorse a zero-tolerance to corruption and bribery. Corruption or bribery is a criminal offence and can destroy our integrity.
• We will uphold all laws and regulations for corruption and bribery (including Myanmar Anti-Corruption Law 2013) in which we operate both at local and other territories.
• All gifts and hospitality must be reasonable, not lavish, made in good faith and acceptable amount is up to 50,000 kyats. Any of greater value than acceptable amount either given or received will require prior approval from the Executive Committee and done under legal and justifiable purposes and need to report annually.
• Golden Cougar will only make charitable donations ethically and legally and do not make donation or contribution to political parties. All donations must be reported and can be disclosed publicly as needed.
• Facilitation Payment is illegal and unofficial. Golden Cougar will not tolerate facilitation payment.
• If anyone is done a payment on behalf of Golden Cougar, that person should always make a receipt and report with detail reasons for payment.

Identification of Risks

Some of activities and areas have particular risks

• Government Projects Tender Activities
• Contracts, Joint Venture and Partnership with government entities.
• Payment and Accept of Gifts and Donations.

Reporting Concern and Protection

• All employees can raise concern about any issue or suspicion of malpractice at the earliest possible stage.
• If employee has any other queries or unsure the activities for corruption or bribery, employee can notify the supervisor and/ or Head/ officer.
• There must be no demotion, penalty and reprisals to every employee for their raising concern, reporting or notifying violations.
• If the employee feels no response or improper response after raising concern, the employee can use the alternative route to notify or report to Head of legal and Compliance department with the Whistle-Blowing Policy.
• Information and Identity of persons making disclosure must not be released and protected and supported under this policy.
• The aim of the policy, to encourage openness and good faith of person rising concern and will support everyone even if they turn out to be mistaken.

Training and Communication

• Every employee and member of Golden Cougar must be provided the awareness training to adhere the implementation of our zero-tolerance to corruption and bribery policy.
• Every partners and stakeholders of Golden Cougar must be communicated with values and principles of Golden Cougar’s Anti-corruption and Anti-bribery policy.

Monitoring and Review

• The Head of legal and Compliance department will monitor regularly the effectiveness of policy, review the implementation and suitability of the policy.
• Internal control system and regular audit system which are effective in countering corruption and bribery must be implemented and done regularly.
• Every employee and members are responsible for the success of the policy.
• Comments, suggestions and queries are invited and should be address to Head of legal and Compliance department.
• The policy must be reviewed and revised regularly and updated as required.