Document IIS-GOV-ABC-001 • Version 1.0 • Effective 01 May 2026
Integrated IT Support Inc. (the “Company”) has zero tolerance for bribery and corruption. The Company conducts its business in compliance with the Canadian Corruption of Foreign Public Officials Act (CFPOA), the bribery and secret-commissions offences of the Criminal Code (Canada), the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act 2010, and equivalent anti-corruption laws of every jurisdiction in which the Company operates.
This Policy applies regardless of geography, role, or seniority. The Company prefers to lose business rather than win it through corruption.
Bribery: offering, promising, giving, requesting, accepting, or receiving anything of value to or from any person — including any public official or commercial counterparty — in order to improperly influence a business decision or to obtain or retain business or an advantage in the conduct of business.
Facilitation Payment: a small, often demanded payment to a low-level public official to expedite a routine, non-discretionary government action (e.g., processing a permit). Facilitation payments are PROHIBITED under this Policy regardless of local custom.
Kickback: an undisclosed payment, rebate, or other benefit returned to a person involved in awarding or influencing business.
Public Official: any officer, employee, or person acting in an official capacity for any government, public-sector entity, state-owned enterprise, public international organisation, or political party, or any candidate for political office, in any country.
Personnel acting on behalf of the Company must NOT, directly or indirectly:
Offer, promise, give, request, accept, or receive any bribe or kickback to or from any person.
Make any facilitation payment.
Provide political contributions on behalf of the Company without prior written approval from the Executive.
Engage any agent, intermediary, distributor, or other third party where there is reason to suspect they may pay bribes on the Company's behalf.
Maintain off-the-books accounts, undocumented payments, or false records of any kind.
Heightened scrutiny applies to any interaction with public officials. In particular:
Any gift, hospitality, travel, or other benefit offered to a public official, of any value, requires PRIOR WRITTEN APPROVAL from the GRC Office.
Personnel must never offer, promise, or give anything of value to a public official to obtain or retain business, secure an improper advantage, or improperly influence any act or decision.
Lobbying activities, if any, must be conducted by registered lobbyists in accordance with the Lobbying Act (Canada) and provincial equivalents.
Permissible: modest meals, branded promotional items, attendance at industry events, and similar courtesies of reasonable value.
Prohibited: cash, cash equivalents, lavish entertainment, personal travel, and any benefit timed to coincide with a pending business decision.
Reportable: any gift or hospitality with a value exceeding CAD $200 per occurrence, or aggregating to more than CAD $500 per recipient per calendar year.
Risk-based due diligence is performed on every agent, intermediary, reseller, distributor, joint-venture partner, and similar third party before engagement, with periodic re-screening thereafter. Standard contracts include:
Anti-bribery representations and warranties.
The right to audit books and records relevant to anti-bribery compliance.
The right to terminate for cause on any credible anti-bribery violation.
All transactions are recorded accurately, completely, and in reasonable detail in the Company's books and records. The Company maintains internal accounting controls sufficient to provide reasonable assurance that:
Transactions are executed in accordance with management's authorisation.
Transactions are recorded as necessary to maintain accountability for assets.
Access to assets is restricted to authorised personnel.
Annual anti-bribery and anti-corruption training is mandatory for all personnel, with enhanced training for finance, procurement, sales, and any role with material public-sector interaction.
All personnel and third parties have a duty to report suspected bribery or corruption immediately through any channel listed in the Code of Conduct (IIS-GOV-COC-001) or the Ethics & Grievance page (iisupp.net/ethics-grievance). The Company prohibits retaliation against any person reporting in good faith.
Violations are subject to disciplinary action up to and including immediate termination of employment or contract, recovery of any unlawful gain, civil action, and referral to law-enforcement authorities. Under the CFPOA, FCPA, and U.K. Bribery Act, individuals can be subject to substantial fines and imprisonment.
Approval and Authority
This document has been reviewed and approved by the Executive Leadership of Integrated IT Support Inc. and is issued under the authority of the Office of the Chief Executive Officer. The document is subject to periodic review and may be amended by the Approving Authority. Material amendments are communicated to all employees and key suppliers within thirty (30) days of issuance.
Signed for and on behalf of Integrated IT Support Inc.
Ahmad
Ahmad — Chief Executive Officer
Integrated IT Support Inc.
Date: 11 May 2026
Approved electronically by Ahmad, Chief Executive Officer, on 11 May 2026. This electronic signature is applied with the authority of the named signatory and is valid under the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Ontario Electronic Commerce Act, 2000.