Anti Bribery Policy

Purpose

This Anti Bribery Policy sets out InTalent Asia’s general approach to preventing bribery, corruption, improper payments, and related unethical conduct in connection with its business activities.

InTalent Asia seeks to conduct its business with integrity and does not support bribery, kickbacks, facilitation payments, or other improper attempts to influence decisions or obtain business advantage through unlawful or unethical means.

Scope

This policy applies generally to directors, management, employees, consultants, contractors, temporary personnel, and other persons acting on behalf of InTalent Asia.

Relevant aspects of this policy may also be communicated to agents, service providers, suppliers, intermediaries, and business partners where appropriate.

Policy Statement

InTalent Asia seeks to discourage bribery and corruption in all forms and to promote lawful, ethical, and professionally responsible conduct in its business dealings. Persons acting on behalf of the company are generally expected not to offer, promise, give, request, receive, authorise, or accept bribes, kickbacks, secret commissions, improper inducements, or other unlawful or unethical benefits in connection with company business.

This applies whether such conduct involves public sector or private sector parties and whether it is intended to influence a decision, secure an improper advantage, or obtain or retain business inappropriately.

Key Principles

InTalent Asia may expect persons acting on its behalf to:

• avoid offering or accepting bribes, kickbacks, improper payments, or unlawful inducements
• avoid requesting or receiving personal benefits in exchange for business influence or preferential treatment
• exercise caution in relation to gifts, hospitality, sponsorships, donations, or entertainment that may create real or perceived impropriety
• maintain reasonable transparency and integrity in approvals, payments, and financial records
• raise genuine concerns regarding suspected bribery or corruption through appropriate channels
• cooperate with internal reviews or investigations where relevant

Areas of Focus

01. Bribes and Improper Payments

Bribes and improper payments are generally prohibited. This includes cash or non cash benefits offered or received to improperly influence a business decision or relationship.

02. Facilitation Payments

Facilitation payments or unofficial payments intended to expedite routine actions are generally discouraged and should not be made unless there is an overriding legal, safety, or emergency consideration.

03. Gifts and Hospitality

Reasonable, proportionate, and lawful business hospitality may be permissible in certain circumstances, but anything excessive, unusual, concealed, or intended to influence judgment should generally be avoided or disclosed as appropriate.

04. Third Parties and Intermediaries

InTalent Asia may consider integrity related factors when engaging certain third parties, agents, consultants, suppliers, or service providers, particularly where they may represent the company or interact with clients, candidates, public authorities, or other stakeholders on its behalf.

05. Books and Records

The company may seek to maintain records and approvals that reasonably reflect business transactions and reduce the risk of concealment or mischaracterisation of improper payments.

Roles and Responsibilities

01. Leadership

Leadership may support an anti bribery culture, oversight of relevant controls, and appropriate escalation of material concerns.

02. Managers

Managers may help reinforce anti bribery expectations, monitor risk areas within their teams, and escalate issues where appropriate.

03. Employees and Representatives

Employees and other persons acting on behalf of InTalent Asia are generally expected to avoid improper conduct, use judgment in risk situations, and raise genuine concerns where appropriate.

Reporting Concerns

Suspected bribery, corruption, improper payments, or related concerns may be raised through appropriate internal channels or designated company contacts.

InTalent Asia may review such matters and determine what action, if any, it considers appropriate, taking into account the seriousness of the concern, evidence available, confidentiality, legal obligations, and operational circumstances.

Monitoring and Review

InTalent Asia may review this policy and related controls from time to time in light of business growth, risk exposure, legal developments, client expectations, and operational needs.

Policy Status

This policy is intended as a general statement of InTalent Asia’s anti bribery approach and internal expectations. It does not create contractual or legally enforceable rights or obligations for any third party, except to the extent required by applicable law.

InTalent Asia may interpret, amend, replace, suspend, or withdraw this policy at any time, subject to applicable legal and regulatory requirements.

Related Standards and Policies

This policy should be read together with the Business Ethics and Code of Conduct, Corporate Governance Policy, Supplier Code of Conduct, ESG Policy, and other related company policies adopted by InTalent Asia from time to time.

Where relevant, elements of this policy may also be supported by the company’s broader management, governance, and quality practices aligned to ISO 9001.

Contact Us

If you have any questions regarding this Anti Bribery Policy, you may contact:

• By email: legal@intalent.asia