Anti-corruption policy «INSIGHT SOLUTIONS» LLC

1. INTRODUCTION.

The core values of “INSIGHT SOLUTIONS” LLC (hereinafter referred to as the “Company”) are adherence to responsible and ethical business practices. The Company aims to promote and maintain the highest standards of ethics in all aspects of its business activities. Company’s reputation for upholding lawful business practices is paramount, and this Policy is designed to uphold these values. Therefore, the Company adheres to a policy of zero tolerance towards bribery and corruption and strives to act honestly and with integrity in all its business dealings and relationships, as well as to implement and enforce effective anti-bribery systems.

2. OBJECTIVES AND PURPOSES OF THE POLICY.

2.1. This Policy sets forth the Company’s position on any forms of bribery and corruption and provides guiding principles aimed at:

  • a) Ensuring compliance with anti-bribery laws, rules, and regulations in any country where the Company operates or where its business may be related;
  • b) Providing employees and individuals associated with the Company the opportunity to understand the risks associated with bribery and encouraging them to be vigilant and effectively identify, prevent, and report any breaches, whether by themselves or others;
  • c) Ensuring appropriate and secure reporting and communication channels and ensuring that any reported information is handled in a proper and effective manner; d) Creating and maintaining rigorous and effective frameworks for addressing any suspected cases of bribery or corruption.

2.2. This Policy applies to all permanent and temporary employees of the Company (including any of its agents, subsidiaries, or associated companies). It also applies to any individual or legal entity connected with the Company or performing functions on behalf of or for the Company, including but not limited to directors, temporary staff, contractors, consultants, seconded employees, agents, suppliers, and sponsors (“associated persons”). All employees and associated persons are expected to adhere to the principles outlined in this Policy.

3. LEGAL OBLIGATIONS OF THE COMPANY AND COMPANY’S EMPLOYEES

3.1. The Policy is designed to ensure full compliance with uzbek legislation on Combating Corruption, as well as correspondent international acts. Since the Company conducts significant business outside the borders of Uzbekistan and continues to expand into emerging international markets, it is crucial that all employees understand the activities prohibited by the Company’s anti-bribery and anti-corruption regulations and ensure compliance with anti-bribery and anti-corruption laws in the countries where the Company operates. Each employee, officer, director, or agent is responsible for adhering to the uzbek legislation on Combating Corruption within their area of responsibility and for reporting any violations to their immediate supervisor.

3.2. All employees and associated persons of the Company are required to:

  • a) Comply with any anti-bribery and anti-corruption legislation applicable in any jurisdiction where they may conduct business;
  • b) Act honestly, responsibly, and with integrity;
  • c) Always uphold and adhere to the Company’s core values, acting ethically, professionally, and lawfully.

3.3. Bribery, including the offering or receiving of bribes, and intermediary activities in bribery are strictly prohibited. Under no circumstances should any funds be allocated, money be set aside, or accounts be created for the purpose of facilitating the payment, receipt, or offering of a bribe.

3.4. The Company recognizes that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or customary in another. However, all employees and associated persons are always required to adhere strictly to the guiding principles outlined in this Policy. If you have any doubts about whether something may be considered bribery or could constitute a breach of this Policy, consult with your immediate supervisor.

3.5. Providing business gifts to clients, customers, contractors, and suppliers is not prohibited, provided the following requirements are met:

  • a) The gift is not made with the intent to influence a third party to obtain or retain business or commercial advantage, or to reward for providing or retaining business or commercial advantage;
  • b) It complies with local laws;
  • c) It is given on behalf of the Company, not personally from the giver;
  • d) It does not include cash or cash equivalents (e.g., gift vouchers);
  • e) It is of an appropriate and reasonable type and value and is given at an appropriate time;
  • f) It is given openly, not secretly;
  • g) The gift is pre-approved by a Company’s director.

3.6. Therefore, it is prohibited to give, promise to give, or offer any reward, gift, or hospitality with the expectation or hope of receiving a business advantage; to reward for an already provided business advantage; or to accept any reward, gift, or hospitality from a third party known or suspected to be offering or providing anything with the expectation of gaining a business advantage for themselves.

3.7. Any payment or gift to a government and/or non-government official or other person to influence or expedite the performance of a routine governmental action or process, commonly known as a “facilitation payment,” is also strictly prohibited.

4. REPORTING PROCEDURE

4.1. It is the contractual obligation and responsibility of all Company’s employees and associated persons to take all reasonable measures necessary to ensure compliance with this Policy, as well as to prevent, detect, and report any suspicions of bribery or corruption. An employee or associated person must immediately report to the Company’s management any information or suspicions they may have that any other employee or associated person plans to offer, promise, or give a bribe, or to request, agree to receive, or accept a bribe. For clarity, this includes reporting your own misconduct. The duty to prevent, detect, and report any instances of bribery and any potential risks lies not only with the Company’s directors but equally with all employees and associated persons.

4.2. The Company encourages all employees and associated persons to remain vigilant and report any illegal behavior, suspicions, or concerns quickly and without undue delay, so that investigations can proceed and appropriate action can be taken promptly. Confidentiality will be maintained during the investigation to the extent that it is practical and appropriate in the given circumstances. The Company is committed to taking appropriate action against bribery and corruption. This may include reporting the matter to the relevant external governmental department, regulatory authority, or police.

4.3. The Company will support anyone who has raised genuine concerns in good faith, even if they turn out to be incorrect, in accordance with this Policy. It also aims to ensure that no one suffers any negative treatment as a result of refusing to participate in bribery or corruption or because they have made a good-faith report of actual or potential bribery or corruption.

5. DOCUMENTATION

5.1. All invoices, receipts, bills, and other documents and records related to transactions with third parties must be prepared and maintained with strict accuracy and completeness. No invoices should be kept “off the books” to facilitate or conceal improper payments.

6. POLICY COMPLIANCE

6.1. The Company’s Director is primarily responsible for ensuring compliance with this Policy and will review its content regularly. The Director is also responsible for monitoring its effectiveness and will provide regular reports on this matter to the Company’s founders.

7. TRAINING

7.1. The Company’s Director will conduct training as needed for all employees to help them understand their duties and responsibilities in accordance with this Policy. The Company’s zero-tolerance approach to bribery will also be communicated to all business partners at the outset of business relationships and subsequently as necessary.

8. FINAL PROVISIONS

8.1. This Policy shall come into effect from the date of its approval by the Director and is mandatory for all employees of the Company.

8.2. All other terms not specified in this Policy will be governed by the current legislation of the Republic of Uzbekistan and the Company’s internal regulations.

8.3. The Director may amend this Policy by order, with such amendments coming into effect upon their approval.

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