ANTI-BRIBERY and ANTI-CORRUPTION POLICY

Nawi Island Pte Limited, South Pacific Marine Pte Limited, and their affiliates, subsidiaries, and related entities (together “Nawi Island”) recognize the importance of honesty, professionalism, impartiality, accountability, transparency, and integrity at each level of the organization and each transaction that we engage in. Bribery and corruption are immoral, unethical, and criminal conduct and can be punishable by law.
Recognising these fundamentals, Nawi Island adopts and implements (including through periodic trainings) this policy for the benefit of our companies, our employees, contractors, customers, and all stakeholders that we deal with directly or indirectly in furtherance of our business. The prevention, detection, and reporting of bribery and other forms of corruption is the responsibility of each one of us.
Zero Tolerance Policy – Nawi Island does not condone and hereby rejects the solicitation, giving and/or acceptance of any undue Advantage (including “facilitation payments”) or Bribery within any of its dealings. This extends to and includes zero tolerance for dishonesty, fraud, nepotism, and illegal trafficking, whether human, drugs, or monies (including under the Financial Transactions Reporting Act 2004 [Fiji]).
Who this policy applies to – This policy must be communicated at the outset of any engagement and directly applies to (but not limited to) all (whether located in or outside of Fiji) of Nawi Island’s:

(a) directors, management, and employees (of any class or definition under the Employment Relations Act 2007 [Fiji]), as a condition of employment

(b) consultants and independent contractors for service as a condition of their engagement; and

(c) contractors and subcontractors for the performance of project and operations related obligations (such as construction, rental lease, supply chain providers, etc) as an implied term of their contract. Nawi Island reserves the right to report any person covered by this policy to the relevant authorities should it suspect a prohibited act under this policy such as giving or accepting an Advantage, Bribery, or Corruption, but by the same token hopes to eliminate and prevent this at all levels. A proven act of giving or accepting an Advantage, Bribery, or Corruption, with an intention to do so, will constitute a breach of contract and or engagement/association, and Nawi Island reserves its right to terminate such contract/engagement/association. Any employee who breaches this policy may face disciplinary action, which could result in dismissal from work.
Gifts and Hospitality – gifts and hospitality can easily be considered an Advantage or Bribery, however in the Fijian context, needs to be adjusted to local accepted customs and traditions. Genuine and acceptable (receiving or providing) gifts and acts of hospitality include:

(a) “one-off” gifts of small items of limited value (and not exceeding Fijian 30 dollars), subject to declaration to management. Gifts between Fijian 31 dollars to 100 dollars, if approved by management (whether accepting or giving), must be for the benefit of the office or organisation. Gifts above Fijian 100 dollars must be returned (if received) or specifically approved for a specific purpose by management if giving.

(b) iTaukei iSevusevu and entertainment (such as dances, food, and kava offerings) and like presentations usually accorded at iTaukei traditional occasions, and this extends to like traditional occasions throughout the various ethnicities in Fiji.

(c) paying the invoice at approved or reasonable business meetings such as over coffee or a meal, subject to legitimate reasons and proper acquittal of receipts.
Political Donations – Nawi Island will remain a-political and will not make any political donations.
Charitable Donations – Any donations by Nawi Island or its employees in the course of business/employment for charitable purposes must first be sanctioned by executive management, and any conflict of interest must be declared. Charitable donations can be in the form of providing services, knowledge, time, or direct financial contributions (cash or otherwise). All charitable donations must be acquitted with proper documentation (whether it be receipts, credits, letters or timesheets). No Nawi Island employee may derive any personal gain through any charitable donation, unless declared prior to the donation and the executive management deem such gain reasonable.
Finance – Nawi Island does not deal with cash payments (except below FJD 200) or in-kind transactions. All transactions must be acquitted with proper receipts, documentation, and evidence, which will be kept in Nawi Island’s system for 7 years, and available for audit.
Raising concern and Protection – Employees, contractors and stakeholders are encouraged to raise a concern about any issue or suspicion of malpractice or report bribery and or corruption, at the earliest possible stage, even if suspected and not having occurred yet or if they are facing pressure and are being victimized. If unsure whether a particular act constitutes bribery or corruption, queries should be raised with management. Nawi Island will afford all protection and confidentiality to its employees and affiliates who in good faith step forward to report bribery or corruption, even if the report turns out to be false.
Monitoring and Reviewing – Nawi Island management will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular checks to provide assurance that they are effective in countering bribery and corruption.
The laws of Fiji apply to this policy. Nawi Island specifically recognises and by this policy implements the law and intent of the Prevention of Bribery Act 2007 [Fiji].

Definitions

Advantage means:

(a) any gift, loan, fee, reward or commission consisting of money or of any valuable security or of other property or interest in property of any description

(b) any employment or contract

(c) any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part

(d) any other service, or favor (other than entertainment), including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted

(e) the exercise or forbearance from the exercise of any right or any power or duty; and

(f) any offer, undertaking or promise, whether conditional or unconditional, of any advantage within the meaning of any of the preceding paragraphs (a), (b), (c), (d) and (e), but does not include any donation into any corporate social responsibility program run by Nawi Island where the accounts of the program(S) are subject to audit.

Bribery means without lawful authority or reasonable excuse offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting an Advantage so to induce or influence an action or decision by another person (including a government official), such as, including but not limited to:

(a) performing or abstaining from performing any act

(b) expediting, delaying, hindering or preventing the performance of an act, by that other person

(c) assisting, favouring, hindering or delaying any person in the transaction of any business

(d) promoting, executing or procuring, or the payment of the price, consideration or other moneys related to such contract, any contract or subcontract with Nawi Island for the performance of any work, the providing of any service, the doing of any thing or the supplying of any article, material or substance.

Corruption means receiving, asking for, offering, authorizing, or giving any gratification as an inducement for a person, customer, business partner, agent, supplier, or other agents to do a favor with a corrupt intent, and includes giving or accepting an Advantage and or Bribery