Anti-Corruption Policy

1. Introduction

Gini Talent LLC ("Gini Talent", "we", "our", or "the Company") is committed to conducting business with integrity and in compliance with all applicable anti-corruption laws and regulations.

This Anti-Corruption Policy applies to all employees, directors, officers, contractors, consultants, and any third parties acting on behalf of the Company.

2. Zero Tolerance Policy

We have a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, including the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and local anti-corruption legislation.

3. Prohibited Conduct

The following conduct is strictly prohibited:

• Offering, promising, giving, or accepting any bribe, whether cash or other inducement
• Receiving or providing kickbacks, secret commissions, or other improper payments
• Making facilitation or "grease" payments to expedite routine governmental actions
• Making political contributions on behalf of the Company without proper authorization
• Making charitable donations or sponsorships as a quid pro quo for business advantages

4. Gifts and Hospitality

Modest gifts and hospitality are acceptable in the normal course of business, provided they are reasonable, proportionate, and given openly without expectation of anything in return.

All gifts and hospitality given or received must be recorded in accordance with Company procedures. Gifts or hospitality that could influence or appear to influence business decisions are prohibited.

5. Third-Party Due Diligence

We conduct appropriate due diligence on all third parties who act on our behalf, including agents, consultants, intermediaries, and joint venture partners.

Third parties must contractually agree to comply with our anti-corruption requirements. We monitor third-party compliance and terminate relationships where violations occur.

6. Record Keeping

We maintain accurate books and records that reflect all transactions in reasonable detail. We do not maintain off-the-books accounts or make false, misleading, or incomplete entries.

All payments must be properly documented with clear business justification. Undocumented or inadequately documented payments are prohibited.

7. Reporting and Whistleblowing

We encourage employees and third parties to report any suspected violations of this Policy. Reports can be made to management, human resources, legal department, or through our confidential reporting channel.

We protect whistleblowers from retaliation. All reports are investigated promptly, thoroughly, and confidentially. Anyone found to have retaliated against a whistleblower will face disciplinary action.

8. Consequences of Violations

Violations of this Policy may result in disciplinary action, up to and including termination of employment. Violations may also expose individuals and the Company to criminal prosecution, civil liability, and reputational damage.

We will cooperate fully with any governmental investigation related to suspected violations of anti-corruption laws.

9. Contact Us

If you have any questions about this Anti-Corruption Policy, please contact us at:
Gini Talent LLC
12 Daniel Rd 318 a3
Fairfield, NJ 07004, USA
Tel: +1 848 339 63 83
Email: compliance@ginitalent.com