Anti-Bribery & Anti-Corruption Policy

Zero tolerance

The Institute prohibits bribery and corruption in any form — direct or indirect, domestic or foreign, public sector or private sector. No business objective justifies a bribe.

Scope

This policy applies to all personnel and to any third party acting on the Institute's behalf. Third-party due diligence is mandatory before engagement.

Specific prohibitions

• Bribes, kickbacks, facilitation payments — regardless of local custom
• Inappropriate gifts, hospitality, sponsorships, charitable donations or political contributions used as a proxy
• Use of intermediaries to circumvent this policy

Due diligence

The Institute conducts risk-based due diligence on partners, suppliers, agents and high-risk engagements, documented in the Institute's engagement records.

Controls

Controls include:

• Segregation of duties in procurement and payments
• Senior approval for high-risk engagements and transactions
• Transparent accounting records — no off-book transactions
• Periodic internal audit of high-risk areas

Training

All personnel receive onboarding and periodic refresher training. High-risk roles receive advanced training, including risk indicator recognition and escalation protocols.

Reporting

Suspicions of bribery or corruption must be reported immediately through the Whistleblowing Channel or to the Compliance Officer at compliance@kstinstitute.com.

ISO 37001 alignment

The Institute aligns its Anti-Bribery Management System (ABMS) to ISO 37001 and pursues certification on the Institute's governance roadmap.