Anti-Bribery & Corruption Policy

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