Anti-Corruption and Business Ethics Policy

To uphold RST Solutions Inc.’s commitment to integrity, transparency, and compliance with all applicable laws and regulations governing anti-corruption and business ethics. This policy aims to safeguard the company’s reputation and foster trust among stakeholders by ensuring ethical conduct in all business dealings.

This policy applies to all employees, directors, officers, contractors, consultants, agents, and third-party representatives acting on behalf of RST Solutions Inc. It encompasses all business activities conducted domestically and internationally.


Prohibition on Bribery:
RST Solutions Inc. strictly prohibits bribery in any form, including but not limited to offering, giving, receiving, or soliciting bribes, kickbacks, or improper payments. This includes cash, gifts, services, loans, or other benefits offered or received with the intention of influencing business decisions or gaining an unfair advantage.

Gifts and Entertainment:
While the exchange of gifts and entertainment is common in business relationships, it must be conducted with discretion and in accordance with applicable laws and company guidelines. Employees may offer or accept modest gifts, hospitality, or entertainment that is reasonable, customary, and consistent with customary business practices. However, all such transactions must be transparent, properly documented, and reported in accordance with company procedures.

Commissions and Payments:
All commissions, fees, discounts, rebates, or other payments made in connection with business transactions must be legitimate, reasonable, and accurately recorded in the company’s books and records. Payments shall not be made to government officials, political parties, or their representatives, except were permitted by law and properly documented.

It is the responsibility of every employee to promptly report any suspected violations of this policy or related concerns to their immediate supervisor, the compliance officer, or through the company’s confidential reporting channels. Retaliation against individuals who report violations in good faith is strictly prohibited and will result in disciplinary action.

RST Solutions Inc. is committed to providing comprehensive training on anti-corruption laws, ethical business practices, and this policy to all employees. Training sessions shall be conducted regularly to ensure awareness and understanding of compliance obligations and ethical standards.

Monitoring and Enforcement:
The company will implement robust monitoring and enforcement mechanisms to ensure compliance with this policy. This may include periodic audits, reviews, and investigations conducted by the compliance team or external parties. Violations of this policy will result in disciplinary action, up to and including termination of employment or contractual relationships, as appropriate.

Related Procedures:

Due Diligence Procedure for Third-Party Representatives:
Prior to engaging with third-party representatives, including agents, distributors, suppliers, and business partners, due diligence must be conducted to assess their integrity, reputation, and compliance with anti-corruption laws and ethical standards.

Gift and Entertainment Approval Procedure:
Employees seeking to offer or accept gifts, hospitality, or entertainment exceeding specified thresholds must obtain prior approval from their supervisor or the compliance officer. Approval shall be based on the principles of transparency, proportionality, and legality.

Commission and Payment Approval Procedure:
All requests for commissions, payments, or financial incentives must be reviewed and approved by authorized personnel in accordance with established policies and procedures. Documentation of approvals and justifications shall be maintained for audit purposes.

Related Laws and Regulations:
In addition to the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, other relevant laws and regulations governing anti-corruption and business ethics may include but are not limited to:

  • The U.S. Securities and Exchange Commission (SEC) regulations
  • The Organization for Economic Co-operation and Development (OECD) Anti-Bribery Convention
  • The United Nations Convention against Corruption (UNCAC)
  • Applicable local laws and regulations in countries where RST Solutions Inc. operates or conducts business.

Note: This policy serves as a guide to ethical conduct and compliance with legal requirements. Employees are expected to exercise good judgment and seek guidance from the compliance team or legal counsel when encountering situations that may pose ethical or legal risks.