Kiroyan Partners maintains a strict zero-tolerance approach to bribery and corruption in all forms. We are committed to conducting our work ethically, transparently, and in full compliance with applicable laws and professional standards.

Overview

This Policy establishes the principles and standards governing the prevention of bribery, corruption, and improper influence in all aspects of our operations.

It applies to all personnel of Kiroyan Partners, including partners, consultants, and support staff, as well as any third parties acting on our behalf.

Our Commitment

We do not offer, give, solicit, or accept any form of bribe or improper advantage, whether directly or indirectly.

This includes:

  • Cash payments or financial incentives.
  • Gifts, hospitality, or benefits intended to influence decisions.
  • Facilitation payments or unofficial fees.
  • Any advantage designed to improperly secure business or influence outcomes.

We maintain independence and objectivity in all engagements, free from undue influence.

Scope and Application

This Policy applies to all professional activities, including:

  • Client engagements and advisory services.
  • Interactions with government officials and regulators.
  • Engagements with media, partners, and third parties.
  • Business development and procurement activities.

All personnel are expected to exercise sound judgment and avoid any situation that may create the perception of improper conduct.

Key Principles

Zero Tolerance

Bribery and corruption are strictly prohibited under any circumstances, regardless of local practices or expectations.

Gifts and Hospitality

Gifts and hospitality must be reasonable, appropriate, and not intended to influence decisions. Any offering that could be perceived as excessive or improper must be avoided.

Interactions with Government Officials

We exercise heightened caution in all dealings with government stakeholders. Any form of improper payment or advantage is strictly prohibited.

Third-Party Conduct

We expect third parties acting on our behalf to uphold standards consistent with this Policy. We do not engage with partners who do not meet these expectations.

Transparency and Record-Keeping

All relevant expenses and engagements must be properly documented and reflect the true nature of the transaction.

Reporting and Accountability

All personnel are required to report any suspected or actual violations of this Policy.

Reports may be made through the firm’s reporting mechanisms. All concerns will be handled with appropriate confidentiality, and individuals who report in good faith will be protected from retaliation.

Governance and Alignment

This Policy is part of Kiroyan Partners’ broader governance framework and should be read in conjunction with:

  • Code of Conduct
  • Conflict of Interest Policy
  • Whistleblowing & Reporting Mechanism

Further Information

This page provides a high-level overview of our Anti-Bribery & Anti-Corruption Policy. Additional guidance may be provided internally or upon request, where appropriate.

For inquiries, please contact:
info@kiroyan-partners.com

Last updated: March 2026.

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