Anti-Bribery & Anti-Corruption Policy

HEOSSI prohibits offering, promising, giving, requesting, agreeing to receive, or accepting anything of value to improperly influence a decision or secure an advantage. This includes public- and private-sector bribery, kickbacks, secret commissions, facilitation payments, and corrupt charitable or political contributions.

Gifts and hospitality must be lawful, infrequent, proportionate, transparent, for a legitimate business purpose, and never intended to influence an active decision. Cash and cash equivalents are prohibited. Records must be complete and accurate; no undisclosed or off-book account may be used.

Risk-based due diligence, written terms, reasonable monitoring, and accurate payment documentation are required for intermediaries and higher-risk relationships. Personnel must disclose actual or potential conflicts of interest and must not use nominees, excessive commissions, vague services, or unusual payment routes to bypass this policy.

Concerns may be reported confidentially to legal@heossi.com. Retaliation against a person who raises a genuine concern or participates in an investigation is prohibited. HEOSSI may investigate, discipline, terminate relationships, recover losses, and report conduct to authorities where appropriate.