Bribery and Anti-Corruption Policy

www.redchip.com.ph

1. Policy Statement

Redchip IT Solutions Inc. (“Redchip”) is committed to conducting business in an ethical, lawful, and transparent manner. We strictly prohibit bribery and corruption in any form—directly or indirectly—whether in the Philippines or abroad. This policy outlines our zero-tolerance approach to bribery and corruption.

2. Purpose

The purpose of this policy is to:

• Ensure compliance with applicable anti-bribery and anti-corruption laws.
• Provide guidance to employees, contractors, suppliers, and business partners.
• Promote ethical business practices and transparency in all dealings.

3. Scope

This policy applies to:

• All employees, officers, and directors of Redchip.
• Contractors, consultants, agents, and third-party representatives.
• Joint ventures, suppliers, vendors, and partners acting on Redchip’s behalf.

4. Definition of Bribery

Bribery is the offering, giving, receiving, or soliciting of anything of value (e.g., cash, gifts, favors, entertainment, services) with the intent to influence the actions of an individual in a position of power or responsibility.


5. Prohibited Conduct

Redchip prohibits:

• Offering, promising, giving, or authorizing a bribe.
• Soliciting or accepting a bribe in any form.
• Using intermediaries (agents or consultants) to commit bribery.
• Facilitation payments or “grease payments” to expedite routine procedures.

6. Gifts and Hospitality

While Redchip recognizes that business gifts and hospitality can be a legitimate part of building business relationships, they must:

• Be of nominal value.
• Not be intended to influence a business decision.
• Be transparent and properly recorded.

Examples of unacceptable gifts/hospitality:

• Cash or cash equivalents.
• Lavish or excessive entertainment.
• Personal favors or benefits to government officials.

7. Dealing with Government Officials

Special care must be taken when dealing with public officials. Offering or providing any benefit to a government official in exchange for favorable treatment is strictly prohibited and may result in criminal liability.

8. Reporting and Whistleblowing

Employees and stakeholders are encouraged to report any concerns or suspected violations of this policy through any of the following:

• Email: compliance@redchip.com.ph
• Anonymous Reporting Box (located in HQ)
• Direct to Legal or HR Department

All reports will be treated confidentially and investigated promptly. Retaliation against whistleblowers is strictly prohibited.

9. Training and Communication

Redchip will provide anti-bribery training to all employees and relevant third parties. This policy shall be made available via:

• Company Intranet/HR Portal
• Employment onboarding kits
• Annual compliance refreshers

10. Consequences of Violation

Any employee or partner who violates this policy will be subject to:

• Disciplinary action, up to and including termination.
• Civil and criminal penalties under applicable laws.

11. Compliance with Laws

This policy shall be read in conjunction with:

• Republic Act No. 3019 – Anti-Graft and Corrupt Practices Act
• Republic Act No. 6713 – Code of Conduct and Ethical Standards for Public Officials and Employees
• The UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA), where applicable

12. Review and Updates

This policy shall be reviewed annually by the Compliance Officer and updated as necessary to ensure relevance with changing laws and business environments.