Anti-Bribery Policy

1. Policy Statement

SKT Global Mining & Services Limited maintains a zero-tolerance stance toward all forms of bribery and corruption. We are committed to conducting our business operations ethically, transparently, and with integrity. This Policy applies to all directors, officers, employees, agents, and contractors across all global and local offices.

2. Legal Frameworks

Our operations are subject to strict anti-corruption laws, and we comply fully with:

• The Zambian Anti-Corruption Act No. 3 of 2012.
• The Indian Prevention of Corruption Act 1988 (governing our parent company).
• International frameworks, including the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010.

3. Prohibited Conduct

Under this Policy, the following activities are strictly prohibited:

• Inappropriate Payments: Offering, giving, receiving, or soliciting bribes, kickbacks, or unauthorized facilitation payments to speed up governmental processes.
• Government Officials: Providing gifts, meals, or expensive hospitality to government officials (such as mining department inspectors, tax auditors, or port authorities) to obtain or retain business advantages.
• Conflicts of Interest: Engaging in activities where personal relationships interfere with operational procurement decisions.

4. Gift & Hospitality Standards

Gifts or corporate hospitality may only be offered or accepted if they are nominal in value, occur infrequently, comply with local laws, and are logged transparently in the Corporate Gift Register. Cash or cash-equivalent gifts are prohibited under all circumstances.