# ANTI-CORRUPTION POLICY
## Preamble
This document defines the Anti-corruption Policy of Horus Solutions. Its objective is to constitute a single reference framework and guide collaborators for all questions relating to proper conduct and corruption.
The company Horus Solutions, which intends to be exemplary in terms of Ethics and Compliance, is committed to respecting ethical rules of business conduct and applies a Zero Tolerance Policy with regard to any form of corruption, public or private, active or passive.
While the Horus Solutions Ethics Charter provides guidance on the most common Ethics and Compliance issues, this Policy constitutes the cornerstone of the Horus Solutions anti-corruption compliance program.
Horus Solutions collaborators are required to conduct their missions within the company and partner companies respecting the highest standards of honesty, integrity and fairness, in accordance with this policy and the guidelines mentioned below.
The same applies to third parties acting on behalf of Horus Solutions, for whom these standards of honesty, integrity and fairness are part of the contractual provisions that require adherence to the Horus Solutions Policy, as well as to all applicable national and international anti-corruption laws.
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## 1. Content of the Policy
### 1.1. Core Values
The values of Horus Solutions are based on integrity, loyalty, compliance and transparency, the absence of retaliation, respect and commitment.
### 1.2. Mission
Horus Solutions wishes to protect its collaborators, its business and its reputation by applying a zero tolerance policy with regard to any form of corruption, public or private, active or passive.
### 1.3. Vision
Horus Solutions intends to continue its growth and aim for excellence, not only with regard to the service rendered through the products made available to clients, but also in the way of working and obtaining results.
It is precisely the role of this policy whose objective is to present briefly to collaborators and stakeholders the risks incurred in case of corruption, while providing a global view of the main elements of the anti-corruption compliance program of Horus Solutions.
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## 2. What You Need to Know: A Brief Overview of Anti-corruption Laws
Horus Solutions, as a company governed by Gabonese law, is directly subject to **Law N°002/2003 of May 7, 2003**, establishing a regime for the prevention and repression of illicit enrichment in the Gabonese Republic.
This anti-corruption law applies to all collaborators of Horus Solutions.
In accordance with this law, it is forbidden for anyone to offer, promise, give or receive, directly or indirectly, any monetary advantage or "anything of value", involving a public official or a private sector person, in order to illegally obtain or retain a market or any other "undue advantage".
More importantly, it is illegal for Horus Solutions or its collaborators to turn a blind eye to undue or potentially fraudulent payments made by other parties, including third parties acting on behalf of Horus Solutions, such as partners or commercial advisers, agents...
Instead of protecting themselves, employees who adopt the "ostrich strategy" face-to-face with undue third-party activity can increase the risk of legal action against Horus Solutions. This is why it is important to have a robust compliance program in place to limit this risk.
Furthermore, double caution should be exercised in relationships with public officials and their relatives.
Violation of anti-corruption laws gives rise to severe criminal and civil penalties, and constitutes a risk to the reputation, activities and markets of Horus Solutions and its collaborators.
Any collaborator who does not respect this policy may be subject to disciplinary action.
"**Anything of value**": corruption is not only monetary in nature. The anti-corruption law generally prohibits offering a person "anything of value" tangible or intangible, in order to secure an undue advantage. According to the law, the expression "anything of value" covers:
* Disproportionate or too frequent gifts or invitations, in particular: restaurants, shows, tickets for different events, trips or accommodation in the absence of any clear professional reason;
* Sponsorships and donations (for example: a charity "sponsored" by a public official);
* Unpaid job offers or internships (for example, for the son or daughter of a public official to win favor or secure the contractual relationship).
The concept of "**undue advantage**" generally refers to something to which a person or company is not entitled, or preferential treatment with a view to:
* Obtain, retain or renew a contract.
* Obtain information on an offer from a competitor.
"**Facilitation payments**": In compliance with the majority of anti-corruption laws, Horus Solutions also prohibits any "facilitation payment", namely unofficial payments of a small amount, paid to employees of competitors, suppliers, customers, with a view to obtaining contracts or maintaining business relations, or to public officials holding low-level positions with a view to accelerating or facilitating the decision process.
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## 3. Our Anti-corruption Compliance Program
Horus Solutions has established an anti-corruption compliance program to reduce the risks of fraud or corruption. It includes in particular the following elements:
"**Specific procedures**": Specific procedures have been adopted regarding major risks related to corruption. These procedures include:
* Requirements relating to the prevention of corruption in engagement with third parties with the implementation of due diligence more or less reinforced depending on the typology of the third party;
* Requirements relating to gifts and invitations;
* Requirements relating to donations and sponsorships.
In addition, guarantees of compliance with anti-corruption laws are provided in purchasing processes, supplier management, and business acquisition as part of external growth.
"**A corruption risk mapping**": The General Management carries out a corruption risk mapping, through interviews with collaborators and operational staff in order to identify risk exposures precisely, evaluate them and define remediation plans with operational staff. This mapping, reviewed annually, is submitted to the risk committee for approval.
"**A training program**": A mandatory training program is made available to collaborators through an e-learning module supplemented by in-person training for collaborators likely to identify acts of corruption by their function.
This initial training is reinforced by a continuous training program in order to take into account regulatory changes but also new corruption cases in the market.
"**Monitoring and audits**": Human Resources is responsible for the supervision and monitoring of the anti-corruption compliance program to ensure that this policy is implemented effectively.
The results of periodic audits are delivered to the Risk Committee at least once a year, including recommendations to strengthen the compliance program if necessary.
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## 4. Role of Each Collaborator
Each collaborator is required to ensure that this policy and its procedures are applied in their business area. The collaborators concerned must participate regularly in the adapted training program, made available to them and at the request of their managers.
In the event of a report of corruption, immediate alerting is a reflex and a duty - even if the collaborators are not directly concerned by the action in question - addressing preferably first their direct supervisor.
These failures can also be reported in the context of the professional alert procedure to the competent administrations that specialize in processing these alerts.
It is a confidential, safe and easy system that each collaborator can use to report concerns related to corruption or other areas, for example cases of accounting fraud, purchasing fraud. Horus Solutions will not tolerate retaliation against collaborators who have, in good faith, raised concerns.
Furthermore, Horus Solutions is committed to protecting personal data confidentiality.
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## 5. Non-compliance with the Policy
In accordance with applicable laws and regulations, any violation of this policy may give rise to disciplinary action in accordance with the internal regulations of Horus Solutions, and may, in addition, result in civil or criminal actions (or both) against collaborators and/or companies of Horus Solutions.
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## 6. Data Recording and Document Retention Related to an Investigation
Horus Solutions policy requires retention of reasonably detailed files and records clearly describing all transactions. Compliance with this policy will be subject to regular audits and internal control procedures.
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