Anti Corruption and FCPA Policy

KYNTRX Logistics USA, LLC 

Anti-Corruption and FCPA Policy

1. Purpose

KYNTRX Logistics is committed to conducting business with integrity, transparency, and in full compliance with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”) and other global anti-bribery regulations.

This policy establishes clear standards to prevent bribery, corruption, and unethical business practices in all operations worldwide.

2. Scope

This policy applies to:

• All employees, officers, and directors of KYNTRX Logistics
• Contractors, consultants, agents, and intermediaries acting on behalf of the company
• Joint venture partners and third parties where applicable

Compliance with this policy is mandatory.

 3. Policy Statement

KYNTRX Logistics maintains a **zero-tolerance policy** toward bribery and corruption in any form.

We strictly prohibit:

• Offering, promising, giving, or authorizing anything of value to improperly influence a business decision
• Accepting bribes, kickbacks, or improper payments
• Engaging in corrupt practices with government officials or private sector partners

4. Prohibited Conduct

Employees and representatives may NOT:

• Offer or provide cash, gifts, travel, entertainment, or anything of value to:
  • Government officials to obtain or retain business
  • Any individual to gain an improper advantage
• Make “facilitation payments” (small payments to expedite routine government actions), unless legally permissible and pre-approved in writing
• Use third parties to indirectly engage in bribery or corruption
• Falsify records or conceal improper payments

5. Government Officials

Special care must be taken when interacting with government officials, including:

* Customs authorities
* Port officials
* Regulatory agencies
* State-owned enterprise employees

Any engagement must be:

* Transparent
* Properly documented
* Compliant with all applicable laws and this policy

6. Gifts, Hospitality, and Entertainment

Reasonable and bona fide business expenses are permitted if they are:

* Modest in value
* Infrequent
* Directly related to legitimate business purposes
* Not intended to influence decision-making

All gifts and entertainment must comply with internal approval thresholds and documentation requirements.

7. Third-Party Relationships

KYNTRX Logistics may be held liable for the actions of third parties acting on its behalf.

Therefore:

* Due diligence must be conducted before engaging agents, brokers, or partners
* Written agreements must include anti-corruption clauses
* Payments must be reasonable, transparent, and properly recorded

8. Recordkeeping and Internal Controls

Accurate and transparent financial records are required at all times.

KYNTRX Logistics will:

* Maintain books and records that reflect transactions accurately
* Prohibit off-the-books accounts or undisclosed funds
* Implement internal controls to detect and prevent corruption

9. Reporting and Whistleblower Protection

Employees and partners are encouraged to report suspected violations of this policy or any applicable law.

Reports may be made:

* To management
* Through designated compliance channels

KYNTRX Logistics prohibits retaliation against anyone who raises concerns in good faith.

10. Training and Compliance

KYNTRX Logistics will:

* Provide periodic anti-corruption training
* Ensure employees understand their obligations
* Monitor compliance with this policy

Failure to comply may result in disciplinary action, including termination.

11. Enforcement and Violations

Violations of this policy may result in:

* Disciplinary action up to and including termination
* Legal action where applicable
* Reporting to relevant authorities

12. Policy Review

This policy will be reviewed periodically and updated as necessary to reflect changes in laws and business operations.

13. Acknowledgment

All employees and applicable third parties are expected to acknowledge and comply with this policy as a condition of their relationship with KYNTRX Logistics.

KYNTRX Logistics is committed to ethical business practices and maintaining the highest standards of integrity across all global operations.