Anti-Bribery and Anti-Corruption Policy

1. Policy Statement

Valen Commodities is committed to conducting business ethically and in accordance with all applicable anti-bribery and anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010. We maintain a zero-tolerance policy toward bribery and corruption in all forms.

2. Scope

This policy applies to all employees, officers, directors, agents, consultants, business partners, and third parties acting on behalf of Valen Commodities in any jurisdiction worldwide.

3. Definitions

3.1 Bribery

Offering, promising, giving, requesting, or accepting any financial or other advantage as an inducement or reward for improper performance of a relevant function or activity.

3.2 Corruption

The abuse of entrusted power for private gain, including bribery, fraud, extortion, and embezzlement.

3.3 Government Official

Any officer, employee, or person acting on behalf of a government, public international organization, political party, or state-owned enterprise.

4. Prohibited Conduct

The following activities are strictly prohibited:

• Offering, promising, or giving bribes to government officials, business partners, or any other party
• Soliciting or accepting bribes from any party
• Making facilitation payments to expedite routine governmental actions
• Providing kickbacks, commissions, or other improper payments in connection with business transactions
• Using third parties to circumvent anti-bribery provisions
• Falsifying books, records, or accounts to conceal improper payments
• Engaging in money laundering activities

5. Gifts and Hospitality

5.1 General Principles

Gifts and hospitality may only be offered or accepted if they are:

• Reasonable in value and frequency
• Transparent and properly recorded
• Given openly, not secretly
• Compliant with local laws and the recipient's policies
• Not given with the intention or expectation of influencing a business decision

5.2 Prohibited Gifts

The following are never permitted:

• Cash or cash equivalents (gift cards, vouchers)
• Gifts or hospitality to government officials without prior approval
• Lavish or extravagant gifts disproportionate to business relationship
• Gifts during active procurement or negotiation processes

6. Third-Party Due Diligence

Before engaging agents, consultants, brokers, or other intermediaries, we conduct:

• Risk-based due diligence on reputation and integrity
• Background checks and reference verification
• Review of prior regulatory actions or corruption allegations
• Assessment of relationships with government officials
• Evaluation of compensation structures for red flags

All third-party agreements must include anti-corruption clauses and audit rights.

7. Books and Records

Valen Commodities maintains accurate books and records that:

• Fairly and accurately reflect all transactions and dispositions
• Maintain reasonable detail for proper identification
• Are supported by appropriate documentation
• Undergo periodic internal audits
• Are retained in accordance with legal requirements

Falsifying records to conceal improper payments is strictly prohibited and may result in criminal liability.

8. Training and Awareness

All personnel receive regular training on:

• Anti-bribery and anti-corruption laws and regulations
• Company policy requirements and procedures
• Red flags and warning signs of corruption
• Reporting obligations and whistleblower protections

9. Reporting and Whistleblower Protection

9.1 Reporting Obligations

All individuals must immediately report:

• Suspected or actual bribery or corruption
• Requests for bribes or kickbacks
• Concerns about third-party conduct
• Potential violations of this policy

9.2 Protection from Retaliation

Valen Commodities prohibits retaliation against individuals who report suspected violations in good faith. Anonymous reporting is available, and all reports are investigated promptly and confidentially.

10. Consequences of Violations

Violations of this policy may result in:

• Disciplinary action, up to and including termination of employment
• Termination of business relationships
• Civil and criminal penalties for the company and individuals
• Significant fines and imprisonment
• Reputational damage and loss of business opportunities

11. Compliance Monitoring

Our compliance program includes:

• Regular risk assessments
• Internal audits and reviews
• Third-party compliance certifications
• Periodic policy updates
• Executive oversight and accountability

12. Contact Information

To report concerns or seek guidance on this policy: