Anti-Bribery & Anti-Corruption

ARCA International is committed to conducting its business with the highest ethical standards and in full compliance with all applicable laws and regulations. This Anti-Corruption and Anti-Bribery Management Policy (the “Policy”) reflects our unwavering adherence to these principles and outlines our commitment to preventing and combating all acts of corruption and bribery.

Prohibited Activities

ARCA International strictly prohibits the following activities:

Offering, promising, giving, or authorizing any payment, gift, or other benefit of value to any government official or employee, directly or indirectly, for the purpose of influencing the official’s action in a manner that will benefit ARCA International.
Offering, promising, giving, or authorizing any payment, gift, or other benefit of value to any private entity or individual, directly, or indirectly, for the purpose of influencing their business decisions or actions in a manner that will benefit ARCA International.
Soliciting, accepting, or receiving any payment, gift, or other benefit of value, directly or indirectly, from any government official or employee or private entity or individual, with the intent to influence the employee’s actions in a manner that will benefit the individual or entity.
Engaging in any other form of bribery or corruption, including extortion, embezzlement, and money laundering.
Failing to report any suspected or known violations of this Policy.

Gifts, Hospitality, and Entertainment

While ARCA International values building and maintaining good relationships with its stakeholders, the offering and receiving of gifts, hospitality, and entertainment must comply with this Policy and applicable laws.

Gifts, hospitality, and entertainment must be:

Of reasonable value.
Made for a legitimate business purpose.
Not prohibited by applicable laws.
In compliance with this Policy.

Employees must:

Obtain prior approval from their managers for any gifts exceeding a specified value.
Disclose any gifts, hospitality, or entertainment received from third parties to their managers.

Facilitation Payments

Facilitation payments, which are small payments made to expedite or secure routine government action, are generally prohibited by ARCA International. However, there may be exceptional circumstances where such payments are permitted by applicable law and no alternative course of action is available. In such cases, prior approval must be obtained from the Compliance Officer and all relevant documentation must be retained.

Reporting and Investigation

Employees are required to report any suspected or known violations of this Policy to their manager or the Compliance Officer immediately. All reports will be investigated promptly and confidentially. ARCA International will not tolerate any retaliation against any employee who makes a report in good faith.

Training and Awareness

ARCA International will provide regular training and awareness programs to all employees on this Policy and applicable laws and regulations. These programs will help employees understand their responsibilities and how to identify and report potential violations.

Monitoring and Auditing

ARCA International will conduct regular audits and reviews to ensure compliance with this Policy. These audits will include, but are not limited to, reviews of financial transactions, gift logs, and hospitality records.

Enforcement

ARCA International will take disciplinary action, up to and including termination of employment, against any employee who violates this Policy. The Company will also cooperate with any government investigation or legal proceeding related to alleged violations of this Policy.

Commitment to Continuous Improvement

ARCA International is committed to continuous improvement of its anti-corruption and anti-bribery compliance program. The Company will regularly review and update this Policy to reflect changes in applicable laws and regulations and best practices.

Definitions

“Bribery” means the offering, promising, giving, or authorizing of any payment, gift, or other benefit of value to any person or entity, directly or indirectly, for the purpose of influencing the recipient’s action in a manner that will benefit the giver.
“Corruption” means the misuse of public power for private gain.
“Facilitation payment” means a small payment made to expedite or secure routine government action.
“Government official” means any person employed by a government agency or holding a public office.
“Third party” means any person or entity other than ARCA International and its employees.