Anti-Bribery & Anti-Corruption Policy

EUSUK Holding LLC conducts business honestly and ethically. We have zero tolerance for bribery and corruption in any form, wherever we operate. This policy applies to our management, staff, agents, contractors, partners and anyone acting on our behalf.

Laws we comply with

We comply with the French anti-corruption framework, including the French Criminal Code and the Sapin II law of 9 December 2016, as well as other laws that may apply to our international activities, such as the UK Bribery Act 2010, Belgian anti-corruption provisions, the Sri Lanka Anti-Corruption Act No. 9 of 2023, Singapore’s Prevention of Corruption Act and the US Foreign Corrupt Practices Act.

What is prohibited

• Offering, promising, giving, requesting or accepting a bribe or any improper advantage.
• Bribing public officials, including employees of state-owned enterprises, to win or keep business.
• Influence peddling (trafic d’influence) and favouritism in public procurement.
• Facilitation payments — small unofficial payments to speed up routine government actions.
• Using agents, consultants or partners to make improper payments on our behalf.

Gifts and hospitality

Modest, occasional and transparent gifts and hospitality are acceptable when they are reasonable and not intended to influence a decision. They must never be given or accepted during a tender process, in cash, or to public officials without prior approval, and must be recorded.

Third parties and due diligence

We carry out risk-based due diligence on agents, distributors, joint-venture partners and suppliers, include anti-corruption clauses in our contracts, and monitor relationships for warning signs.

Accurate records

All payments, expenses and transactions must be accurately recorded in our accounts. No off-book accounts are permitted.

Reporting concerns

Anyone with a concern should report it as soon as possible to info@eusukholding.com. Reports are handled confidentially and we will not tolerate retaliation against anyone who raises a concern in good faith, in line with French whistleblower protection rules.

Consequences

Breaches of this policy may lead to disciplinary action, termination of contracts and reporting to the relevant authorities.

Contact us

If you have any questions about this policy, please contact us at info@eusukholding.com or support@eusukholding.com, or write to our head office: 40 Rue du Louvre, 75001 Paris, France. You can also reach any of our offices:

• Paris, France — European Head Office40 Rue du Louvre, 75001 Paris, France
• London, United Kingdom — UK OfficeRex House, 4th Floor, 4–12 Regent Street, London SW1Y 4PE, United Kingdom
• Brussels, Belgium — EU OfficeAvenue Louise 279, 1050 Brussels, Belgium
• Colombo, Sri Lanka — South Asia OfficeLevel 26, East Tower, World Trade Center, Echelon Square, Colombo 00100, Sri Lanka
• Singapore, Singapore — Asia-Pacific OfficeLevel 42, Suntec Tower Three, 8 Temasek Boulevard, Singapore 038988
• New York, United States — North America Office14 Wall Street, 20th Floor, New York, NY 10005, USA