Anti-Bribery and Corruption Policy

Auren Institute

January 2026

Auren Institute Anti-Bribery and Corruption Policy

1. Purpose

Auren Institute is committed to conducting its activities with integrity, fairness, and transparency.

This policy establishes a clear framework to prevent, identify, and address bribery and corruption risks across all operations.

2. Scope

This policy applies to:

• Employees, contractors, and consultants
• Directors and management
• Partners, suppliers, and third parties acting on behalf of Auren Institute

3. Definition of Bribery and Corruption

• Bribery: Offering, giving, receiving, or soliciting anything of value to influence a decision or gain an improper advantage.
• Corruption: Abuse of entrusted power for private gain, including conflicts of interest, facilitation payments, and improper influence.

4. Policy Statement

Auren Institute adopts a zero-tolerance approach to bribery and corruption.

Bribery in any form, direct or indirect, is strictly prohibited, regardless of local customs or business practices.

5. Prohibited Conduct

The following are strictly prohibited:

• Offering or accepting bribes, kickbacks, or inducements
• Facilitation payments (small payments to speed up routine actions)
• Improper gifts, hospitality, or sponsorships intended to influence decisions
• Undisclosed conflicts of interest
• Misuse of funds for unethical purposes

6. Gifts and Hospitality

Gifts and hospitality must:

• Be reasonable, proportionate, and infrequent
• Not influence, or appear to influence, business decisions
• Be transparently recorded where applicable

Cash or cash-equivalent gifts are strictly prohibited.

7. Conflicts of Interest

All individuals must:

• Disclose any personal or financial interests that may conflict with Auren Institute’s interests
• Avoid situations where objectivity may be compromised

8. Responsibilities

Management

• Implement effective controls and oversight
• Promote a culture of ethical behaviour
• Ensure due diligence on third parties

Employees and Associates

• Comply with this policy at all times
• Exercise professional judgement and integrity
• Report any suspected misconduct

9. Third-Party Risk Management

Auren Institute will:

• Conduct due diligence on partners, agents, and suppliers
• Ensure contracts include anti-bribery clauses
• Monitor third-party activities where relevant

10. Reporting Concerns

Any suspicion of bribery or corruption must be reported immediately to:

• Senior Management or designated compliance contact

Auren Institute ensures:

• Confidential reporting channels
• Protection from retaliation for whistleblowers

11. Investigation and Enforcement

• All allegations will be investigated promptly and fairly
• Breaches may result in disciplinary action, contract termination, or legal action
• Authorities may be notified where required

12. Monitoring and Review

This policy will be:

• Regularly reviewed and updated
• Supported by internal controls and periodic assessments

13. Training and Awareness

Auren Institute will:

• Provide awareness training where necessary
• Ensure stakeholders understand their responsibilities

Conclusion

Bribery and corruption undermine trust, distort decision-making, and expose organisations to legal and reputational risks.
Auren Institute is committed to ethical business practices that support sustainable growth, strong partnerships, and long-term credibility.