Policy Statement

Glocalads is committed to maintaining the highest standards of integrity and ethical conduct in all business activities. We do not tolerate any form of bribery, corruption, or unfair business practices. This Policy applies to all employees, directors, consultants, contractors, agents and any third parties acting on our behalf.

Scope of Policy

This Policy applies to all of our business activities worldwide, including but not limited to:

• Interaction with government officials and private sector entities
• Relationships between business partners and suppliers
• Gifts, entertainment, and other business etiquette
• Political donations and charitable giving
• M&A and joint venture activities

Prohibited Conduct

In accordance with this policy, the following actions are strictly prohibited:

• Directly or indirectly offering, promising, giving, soliciting or accepting bribes of any kind
• Any improper payment made to obtain or retain business or an improper advantage
• Bribery through third parties, such as agents, consultants, or joint venture partners
• Falsification of records or accounts to cover up bribery
• Failure to comply with applicable anti-bribery and anti-corruption laws

Gifts & Hospitality

We allow reasonable, modest business gifts and entertainment, but only if they meet the following criteria:

• Infrequent and moderate
• For legitimate business purposes
• Does not constitute or may be considered an attempt to influence business decisions
• Comply with local laws and customs
• Fully transparent and documented

Political contributions

Glocalads does not make political contributions in the name of the company. Individual employees' political contributions must be made entirely in a private capacity and must not use company resources or attempt to represent the company.

Charitable giving

All charitable donations must be made for a legitimate purpose and must not be used as a cover for bribery. Donations must be properly approved and fully documented.