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(FCPA) Compliance Policy

(FCPA) COMPLIANCE POLICY

1. Purpose

This Policy sets forth the standards and procedures that all employees, officers, directors, contractors, consultants, agents, and business partners of Urbantronics Corporation LLP must follow to ensure compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and all applicable anti-corruption laws globally.

The purpose of this Policy is to:

  • Prevent bribery and corrupt practices in business dealings
  • Ensure accurate and transparent record-keeping.
  • Protect the reputation, integrity, and sustainability of Urbantronics Corporation LLP

2. Scope

This Policy applies to:

  • All employees (full-time, part-time, temporary, or contract).
  • Board members and officers.
  • Consultants, representatives, distributors, joint venture partners, and third-party intermediaries acting on behalf of Urbantronics Corporation LLP.
  • All operations, transactions, and business activities worldwide.

3. Key Principles of the FCPA

a. Anti-Bribery Provisions : The FCPA prohibits offering, promising, authorizing, or giving anything of value, directly or indirectly, to:

1. Foreign government officials.

2.Officials of public international organizations (e.g., UN, World Bank).

3.Political parties, party officials, or candidates for office.

B. Anything of value” includes (but is not limited to):

1.Cash payments.

2.Gifts, hospitality, or travel.

3.Charitable donations.

4.Employment opportunities or internships.

5.Discounts, services, or favors.

4. Accounting Provisions

The FCPA requires companies to:

  1. Maintain accurate books, records, and accounts that fairly reflect all transactions.
  2. Implement and maintain internal accounting controls to prevent and detect corrupt practices.

5.Policy Statements

  1. Zero Tolerance for Corruption
  2. Urbantronics Corporation LLP strictly prohibits bribery, facilitation payments, or any form of corrupt influence to gain or retain business advantage.
  3. Gifts, Hospitality, and Entertainment
  4. Gifts and hospitality may only be offered if they are reasonable, transparent, occasional, and lawful.
  5. Any gifts or hospitality must be pre-approved by the Designated Partner.
  6. Cash or cash-equivalent gifts are strictly prohibited.

6.Facilitation Payments

Urbantronics Corporation LLP does not permit facilitation payments, even if considered “customary practice” in certain countries.

7.Political and Charitable Contributions

Urbantronics Corporation LLP does not permit facilitation payments, even if considered “customary practice” in certain countries.

8.Third-Party Engagements

  1. All third parties (agents, distributors, consultants, joint venture partners) must undergo due diligence.
  2. Third-party contracts must include anti-corruption compliance clauses.
  3. Payments to third parties must be proportionate and documented.

9.Record-Keeping and Transparency

  1. All financial transactions must be accurately recorded.
  2. Off-the-book accounts, slush funds, or mischaracterized expenses are strictly prohibited.
  3. Expense reports must include original receipts and proper documentation.

10.Training and Awareness

  1. Mandatory FCPA compliance training will be conducted for all employees and relevant third parties.
  2. Refresher training will be provided annually.

11.Responsibilities

  1. Board of Directors – Oversight of compliance framework and periodic review.
  2. Compliance Officer – Implementation, monitoring, reporting, and training related to FCPA compliance.
  3. Managers – Promote ethical conduct within teams and ensure adherence to policy.
  4. Employees & Representatives – Read, understand, and comply with this policy; immediately report violations or suspected breaches.

12.Reporting & Whistleblower Protection

  1. Employees and stakeholders must promptly report any suspected violation the Compliance Officer.
  2. Reports will be investigated fairly, confidentially, and without retaliation against the reporter.
  3. Whistleblowers are protected under this Policy and applicable law.

13.Disciplinary Action

      1. Any violation of this Policy may result in disciplinary action, up to and including termination of employment, termination of business relationship, and legal prosecution.
    2. Urbantronics Corporation LLP may seek damages and indemnification for losses arising from violations.

14.Monitoring and Review

  1. Compliance audits will be conducted periodically to verify adherence.
  2. This Policy will be reviewed annually and updated to reflect changes in law, regulations, and best practices.

15.Acknowledgment

  1. All employees and third parties subject to this Policy must sign an acknowledgment confirming that they:
    1. Have read and understood the Policy.
    2. Agree to comply with its terms.
    3. Are aware of the consequences of non-compliance