1. Policy Statement
Valkyrien Holding Ltd maintains a zero-tolerance approach to bribery and corruption in all forms.
2. Scope
This policy applies to:
- Employees and directors
- Intermediaries
- Consultants
- Partners and counterparties
3. Prohibited Conduct
The following are strictly prohibited:
- Offering, promising, or giving any undue advantage
- Accepting bribes or improper benefits
- Indirect bribery via third parties
- Facilitation payments
4. Third-Party Risk
The Company recognizes that corruption risk may arise through intermediaries.
Accordingly:
- Due diligence is conducted prior to engagement
- Contracts include compliance clauses
- Relationships are subject to ongoing review
5. Gifts & Hospitality
Permitted only if:
- Reasonable and proportionate
- Not intended to influence decisions
- Fully compliant with applicable laws
6. Reporting
Any suspicion must be reported internally.
Anonymous reporting channels may be implemented where appropriate.
7. Enforcement
Non-compliance may result in:
- Immediate termination
- Legal action
- Notification to authorities

