Anti-Bribery Corruption (ABC) Policy

Last modified: December 2025

1. COMMITMENT TO INTEGRITY 

1.1  Gateway Consultancy Pakistan (“ZUS Pakistan”) and its group of companies (individually or collectively,
“Group”) are committed to conducting its business ethically and with integrity.

1.2  This Anti-Bribery & Corruption Policy (“Policy”) sets out the framework to identify, prevent and report any bribery or corruption activities that could negatively impact the Group's reputation and legal standing.

1.3  This Policy is non exhaustive and serves as a guide on how to deal with improper solicitation, bribery and corrupt acts which may arise in the Group’s daily operations.

1.4  Compliance to this Policy is mandatory and shall be read together with all applicable laws in all jurisdictions where the Group carries on its business(collectively, “Applicable Laws”).

1.5 Any breach or circumvention of this Policy may result in legal action, which may include a termination of contract, employment or service (as applicable).

2. SCOPE AND APPLICABILITY 

2.1 This Policy is applicable to all employees, including but not limited to those who are full time, probationary, contract, temporary employees, casual workers, trainees, secondees, interns and consultants (collectively, “Personnel”), directors of the Group (“Directors”) and all third parties, including but not limited to, licensees, franchisees, suppliers, distributors, vendors, contractors, sub-contractors, service providers, advisers, consultants, agents, representatives, business associates, joint venture partners, outsourcing providers and other persons or entities engaged in business dealings with the Group ("Third Parties”). 

2.2  It is the responsibility of the Third Parties to comply with this Policy. If there is any violation of this Policy, then the Group retains the right to cancel its business dealings with the Third Parties.

2.3  Any arrangement between the Group and the Third Parties shall be deemed to include specific provisions requiring the Third Parties to comply with minimum standards and procedures relating to anti-bribery and corruption as set out in this Policy.

2.4  This Policy applies to all countries worldwide where the Group carries on its business and applies equally to its business dealings in the private sector and public sector.

3. REPORTING OF POLICY VIOLATIONS & WHISTLE-BLOWING 

3.1 Any Personnel or Third Parties who have any queries, knowledge or information about any unethical business practices relating to the Group are encouraged to contact ZUS Ethics Committee.

Gateway Consultancy Pakistan Ethics Committee can be contacted via: 

E-mail : syedshams@gatewayconsultancy.pk

[Address : Office No. 15, 4th Floor, Pakland City Centre, I/8 Markaz Islamabad]

3.2  All reports to ZUS Ethics Committee are treated in the strictest confidence unless otherwise required by the Applicable Laws. Reports may be made without incurring fear of reprisal regardless of the outcome of any investigation.

3.3  The Group will not hesitate to lodge a report to the relevant authorities for their further action.

3.4  The Group may, at its discretion, reward the whistle blowers if the reported Personnel or Third Parties is found guilty by the courts.

4. BRIBERY AND CORRUPTION 

4.1 All forms of Bribery and Corruption are strictly prohibited and all Directors, Personnels and Third Parties must refrain from engaging in any Bribery and Corruption practices. 

4.2  For the purpose of this Policy:-“Bribery” shall mean the offering, promising, giving, accepting or soliciting of an undue advantage of any value (which could be monies or otherwise), directly or indirectly, in violation of the Applicable Laws, as an inducement or reward for a person acting or refraining from acting in relation to the performance of that person's duties. “Corruption” shall mean the abuse of entrusted power or position to obtain a personal gain or benefit.

4.3  All business decisions and actions must be based on the best interests of the Group and must be arm’s length basis even if the transaction is with a related party. Such business decisions and actions must not be motivated by personal considerations or relationships. Any relationships and friendships between Third Parties, Directors and Personnels must be declared to the ZUS Ethics Committee prior to any dealings with such Third Parties, particularly but not limited to any purchasing, procurement or tender process. In this regard, “related party” shall be interpreted in the broadest manner and includes immediate family, relatives and friends or any company in which any Director, Personnel or the family, relative or friends of the Director or Personnel has an interest.

4.4  Where there is evidence or even suspicion of improper behavior during and after any purchasing, procurement or the tender process, it must be reported to the ZUS Ethics Committee for appropriate action to be taken.

5. GIFTS, ENTERTAINMENT, HOSPITALITY & TRAVEL 

5.1  The Group understand that, in certain cultures or situations, gift giving and receiving may be common practice to build business relationships or as part of business etiquette. Therefore, Directors, Personnel and Third Parties may give and receive gifts, entertainment, hospitality and travel (collectively, “Gifts”) SUBJECT ALWAYS that such gift giving and receiving acts are reasonable and appropriate in the normal course of business and is in line with this Policy.

5.2  All Directors, Personnel and Third Parties are strictly prohibited from offering and/or receiving hospitality and entertainment that is excessive, inappropriate, illegal or given in response to or in anticipation of a favourable business decision.

5.3  In determining whether such Gifts are permissible, Directors, Personnels and Third Parties should take into consideration, among others, the intention and timing, transparency, frequency, value (i.e. whether it is within the Group’s approved threshold), legality and compliance with the other party’s policies and rules of such Gifts. 

5.4  The Group does not prohibit normal and appropriate gestures of hospitality and goodwill (whether given to or received from Third Parties) so long as the giving or receiving of Gifts meets the following requirements:- 

(a)  it is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favors, positions or benefits;

(b)  it complies with all the Applicable Laws;

(c)  it is given in the name of the company or entity, not in an individual’s name;

(d)  it is appropriate and proportionate for the circumstances, considering the value of the Gifts and frequency with which the Gift has been given to or received from (for example, it is customary for gifts to be given during festive seasons or events or as a token of appreciation);

(e)  it does not include cash or a cash equivalent (for example, like vouchers or an expensive watch or anything that can be easily converted to cash) or personal services;

(f)  it is given or received openly, not discreetly;

(g) it is of an appropriate type and value, and given at an appropriate time, taking into account the reason for the Gifts;

(h)  it is not offered to, or accepted from, a government official or representative, politician or political party; and

(i)  it is appropriately approved and properly recorded.

5.5  Some other examples of acceptable Gifts are as follows: 

(a)  Exchange of gifts at company-to-company level;

(b)  Gifts given by or to external institutions or individuals for the Group’s or the other party’s official functions, events and celebrations (for example, commemorative or door gifts);

(c)  Token gifts of nominal value bearing the Group’s logo in any promotional or brand building exercise; and

(d)  Refreshments or meals during meetings or work-related conferences and/or seminars.

5.6 Some Gifts may cause or appear or be perceived to viewed as a bribe and may adversely tarnish the reputation of the Group. In this regard, the following are strictly prohibited: 

(a)  any Gifts that are illegal or in breach of the Applicable Laws or this Policy;

(b)  any Gifts offered to a government official or its nominee/related parties to facilitate or expedite any matters;

(c)  any Gifts involving Third Parties currently engaged in a tender or competitive bidding process;

(d)  any Gifts made in cash or cash equivalent;

(e)  any Gifts which are given or offered in return for something else such as business advantage; or

(f)  any Gifts that are paid for personally with the intention of avoiding the need to declare or seek approval for.

6. CORPORATE SOCIAL RESPONSIBILITY, DONATIONS AND SPONSORSHIPS 

6.1  The Group believes in and practices Corporate Social Responsibility (“CSR”). Therefore, the Group supports CSR-related donations, sponsorships and contributions (collectively, “Contributions”).

6.2  However, the following are strictly prohibited:-

(a) such request or giving of the Contributions comes with a direct/indirect suggestion, hint, understanding or implication that some outcome is expected or required;

(b) such Contribution is made directly or indirectly to a recipient as a way of influencing, reasonably perceived as influencing or obtaining an advantage in business transactions;

(c) any Contribution that is illegal or in breach of any Applicable Laws; or

(d) anyContributionthatisexcessiveormayotherwisetarnishthereputationoftheGroup.

6.3  All Directors and Personnels shall ensure that all donations and sponsorships on behalf of the Group are given through proper and legal channels and that the Contributions are not used as a scheme to circumvent any prohibitions on bribery. All giving of the Contributions are subject to prior approval of the Group.

7. POLITICAL CONTRIBUTIONS & PUBLIC OFFICIALS 

7.1 The Group will not make any Contributions, whether in cash, kind or by any other means, to support any political parties, candidates and/or government officers. 

8. FACILITATION OR EXTORTION PAYMENTS 

8.1  The Group strictly prohibits accepting or giving, whether directly or indirectly, any Facilitation Payment and any Extortion from or to any Third Parties including but not limited to public officials and government officers.

8.2  For the purpose of this Policy:-

“Facilitation Payment", “Duit Kopi” or kickbacks, means any illegal or unofficial payment given in return for services or benefits in which the payer is legally entitled to receive without making such payment. For example, a Facilitation Payment is paid to a government official so that approval or license may be granted expeditiously.

“Extortion Payment" is where a payment or gratification is demanded or threatened.

9. UPHOLDING INTEGRITY AND COMPLIANCE OF THIS POLICY 

9.1  All Directors, Personnel and Third Parties must read, understand and comply with this Policy.

9.2  Any Directors, Personnels and Third Parties who refuse to give or receive bribes or allow himself/herself to be corrupted will not be penalised irrespective of any loss of business dealings.

9.3  All Directors, Personnel and Third Parties are equally responsible for the prevention, detection and reporting of all forms of bribery and corruption.

9.4  All Directors, Personnel and Third Parties must refrain from any activities that could lead to, or imply, a breach of this Policy. Legal action may also be taken if the Group’s interests have been jeopardised as a result of non-compliance of this Policy.