Dunyo Cargo: Anti-Corruption and Anti-Bribery Policy

LLC “Dunyo” conducts its activities ethically and honestly. We are committed to a zero-tolerance approach to corruption and bribery, and we pledge to act professionally, fairly, and with integrity in all business dealings and relationships.
We strictly comply with all applicable anti-corruption laws and regulations of the Republic of Tajikistan, as well as internationally recognized anti-bribery standards.
This document outlines the fundamental principles and rules that must be followed by all employees and business partners of the company.

• Corruption / Bribery – Offering, giving, requesting, or receiving illegal payments, gifts, services, or any other benefit to improperly influence a business decision.
• Agent – An individual or legal entity acting on behalf of LLC “Dunyo” in dealings with third parties.
• Conflict of Interest – A situation where personal interests may influence objective decision-making.
• Donation – A voluntary contribution (financial or material) made in support of a cause without expecting any benefit in return.
• Employee – All persons employed by LLC “Dunyo” regardless of position or employment type (permanent, temporary, contractors, consultants, or agents).
• Facilitation Payment – Small payments made to public officials to expedite routine services to which the payer is legally entitled.
• Kickback – A portion of an improper payment returned to the individual who helped secure it.
• Public Official – Any person holding a government position or working in a state-owned enterprise or public function.
• Third Parties – Any individuals or organizations that interact with LLC “Dunyo”, including clients, suppliers, public officials, partners, and consultants.

This policy applies to all employees of LLC “Dunyo” and to third parties working with or on behalf of the company.
It must be communicated to all new employees upon hiring and to all partners at the start of contractual relations.

LLC “Dunyo” allows reasonable gifts and hospitality only if they:

• Are not intended to secure an improper advantage or create an obligation
• Comply with business norms and do not create a conflict of interest
• Are of appropriate value and not excessive
• Are transparent and not hidden

• Aim to gain commercial advantage or influence decisions
• Include cash, gift cards, or monetary equivalents
• Are given during tenders, negotiations, or contract signing

LLC “Dunyo” strictly prohibits:

• Facilitation payments (unofficial payments to expedite lawful services)
• Kickbacks (improper payments shared with facilitators)
• Any form of bribery or concealed payments

Employees are prohibited from:

• Offering or accepting bribes, gifts, or favors in exchange for business decisions
• Making or receiving unlawful payments from third parties
• Maintaining false accounting records or creating fictitious documents
• Pressuring colleagues who refuse to participate in corrupt practices

• Promptly report any suspicious behavior or corruption-related activities
• Accurately document business expenses, gifts, and entertainment
• Refuse to engage in any form of corruption

LLC “Dunyo” guarantees protection for employees who report corruption in good faith.
Any form of retaliation, dismissal, or harassment against whistleblowers is strictly prohibited.

• Company management is responsible for policy compliance and staff training.
• This policy is reviewed annually to ensure relevance and legal alignment.
• Anti-corruption practices are subject to internal audits.

This policy is mandatory for all employees and partners of LLC “Dunyo.”
Violations may result in disciplinary and legal action.
Employees with questions or concerns should contact their supervisor or the compliance department.

Date of last update: January 5, 2025