ANTI-BRIBERY AND CORRUPTION POLICY

Layons Construction Ltd
(Building & Construction Industry)

1. Purpose

This policy sets out the rules and principles that all employees, directors, shareholders, consultants, contractors, suppliers, and third parties of Layons Construction Ltd (“the Company”) must adhere to.

The policy explains the measures we take to maintain high ethical standards and demonstrates our commitment to lawful, honest, and transparent business practices within the building and construction industry.

2. Commitment to Integrity

Integrity is a core value of Layons Construction Ltd. We are committed to conducting all business activities lawfully, ethically, and with integrity.

All forms of bribery and corruption are strictly prohibited and will not be tolerated. No individual working for or on behalf of the Company may engage in corrupt practices in dealings with clients, suppliers, subcontractors, regulators, or any other parties.

Bribery and corruption are criminal offences. Individuals found engaging in such activities may face disciplinary action, dismissal, substantial fines, and/or imprisonment.

3. Scope

This policy applies to:

  • All operations, projects, and geographic locations of Layons Construction Ltd

  • Any subsidiary or affiliated companies

  • All directors, officers, employees (permanent, temporary, or casual), consultants, and contractors (“Personnel”)

  • All third parties acting for or on behalf of the Company, including agents, suppliers, subcontractors, joint venture partners, and consultants

All Personnel must confirm that they have read, understood, and will comply with this policy. Third parties may be required to formally agree to observe its provisions.

4. What Constitutes Bribery and Corruption

Bribery occurs when:

  • A financial or other advantage is offered, given, or promised to induce or reward someone to perform their duties improperly; or

  • A financial or other advantage is requested, agreed to, or accepted to induce or reward improper performance.

Bribes may include, but are not limited to:

  • Cash or cash equivalents

  • Gifts or entertainment

  • Kickbacks or secret commissions

  • Excessive discounts or commissions

  • Facilitation (“grease”) payments

  • Political or charitable donations intended to secure an improper advantage

  • Any other item or benefit of value

5. General Prohibition

Layons Construction Ltd operates a zero-tolerance approach to bribery and corruption.

Offering, promising, giving, requesting, or accepting bribes—directly or indirectly through third parties—is strictly prohibited. This applies to interactions with both public officials and private individuals.

6. Gifts and Hospitality

Reasonable and proportionate gifts or hospitality given or received in good faith for legitimate business purposes may be acceptable, provided they:

  • Are modest and infrequent

  • Are not intended to influence business decisions

  • Do not create an actual or perceived conflict of interest

Lavish, excessive, or inappropriate gifts or hospitality are prohibited.

Gifts & Hospitality Thresholds:

  • Gifts: USD 75 (or local equivalent)

  • Hospitality: USD 150 (or local equivalent)

  • Cash gifts are strictly prohibited

All reportable gifts and hospitality must be recorded in the Gifts & Hospitality Register.

7. Facilitation Payments

Facilitation (“grease”) payments—small unofficial payments made to expedite routine actions—are illegal and strictly prohibited.

Personnel and third parties acting on behalf of the Company must not offer, request, or make such payments under any circumstances.

8. Third Parties (Agents, Suppliers, Subcontractors, Partners)

Layons Construction Ltd may be held liable for corrupt actions committed by third parties acting on its behalf.

Before engaging third parties:

  • Appropriate due diligence must be conducted

  • Contracts must include anti-bribery and corruption clauses

The Company will not engage or continue working with any party known or reasonably suspected to be involved in bribery or corruption.

9. Compliance and Training

Personnel will receive appropriate training to understand and comply with this policy.

Periodic confirmations of compliance may be required, including annual declarations where applicable.

10. Whistleblowing

  • All reports of suspected bribery or corruption will be treated confidentially

  • Retaliation against any person who raises a concern in good faith is strictly prohibited

Concerns should be reported through the Company’s designated reporting channels.

11. Breach of Policy

Any breach of this policy may result in:

  • Disciplinary action, up to and including dismissal

  • Termination of contracts with third parties

  • Referral to relevant law enforcement or regulatory authorities where appropriate

12. Review

This policy will be reviewed periodically and updated as necessary to reflect changes in legislation, industry standards, and best practices.

Approved by:
Management Team
Layons Construction Ltd