1. Purpose
Surplus-Gy is committed to conducting business with integrity and in full compliance with all applicable laws and regulations. This Anti-Bribery Policy is designed to ensure that all employees, vendors, and partners understand and adhere to our zero-tolerance approach to bribery and corruption.

2. Scope
This policy applies to all employees, vendors, contractors, and third parties acting on behalf of Surplus-Gy, regardless of location.

3. Policy Statement

• Bribery in any form, whether direct or indirect, is strictly prohibited.
• No employee or representative of Surplus-Gy may offer, give, solicit, or accept any form of bribe, whether in cash, gifts, or other benefits, to or from any individual, organization, or public official.
• Surplus-Gy prohibits the use of company funds or resources to secure an improper advantage.

4. Reporting and Enforcement

• Any suspected bribery must be reported to the Compliance Officer or through our confidential reporting system.
• Violations of this policy will result in disciplinary action, up to and including termination of employment or business relationship.

5. Training
Regular training will be provided to employees to ensure understanding and compliance with this policy.