Scope of Application

This policy applies to:

• All Alghanim Healthcare employees, management, and board members, including full time, part time, contract, and temporary staff.
• Business partners, suppliers, contractors, and third party representatives acting on behalf of AHC.
• All business activities across our local and international operations, including interactions with government bodies, healthcare professionals, and commercial partners.

Key Policy Guidelines

1. 1. Prohibition of Bribery and Corruption
      AHC personnel and affiliates must never:
      • Offer, provide, or accept any form of bribery, including money, gifts, favors, or incentives, to influence business decisions. (Quid Pro Quo)
      • Engage in activities that could be perceived as corrupt or unethical, such as kickbacks, facilitation payments, or preferential treatment.
      • Participate in business dealings that could create conflicts of interest or undermine our ethical commitments.
   2. Gifts and Hospitality
      While AHC recognizes that business hospitality is a customary practice, it must always comply with the following guidelines:
      • Gifts must be of nominal value, appropriate, and consistent with local customs.
      • No gifts, payments, or benefits should be offered to government officials or healthcare professionals to gain business advantages.
      • Any hospitality provided must be duly approved, recorded, and align with our compliance standards.
      • Permissible expenditures include any journal subscription, medical/educational event, sponsorship, speaker fees, training fees, group meetings, business meals, actual travel and lodging expenses directly related to such activities.
   3. Interactions with Government Officials
      Given the highly regulated nature of the healthcare industry, interactions with government officials and public sector representatives must:
      • Be conducted transparently and ethically.
      • Comply with local and international anti corruption regulations.
      • Be documented to reflect legitimate business purposes only.
   4. Third Party Due Diligence
      Before engaging with any third party partners, suppliers, or consultants, AHC will:
      • Conduct thorough due diligence to assess compliance risks.
      • Require partners to adhere to AHC’s anti bribery standards through contractual obligations.
      • Regularly monitor and audit business relationships to ensure ongoing compliance.
   5. Reporting and Whistleblowing
      AHC encourages all employees and stakeholders to report suspected violations of this policy without fear of retaliation. Reports can be made confidentially through:
      • Dedicated compliance email channels.
      • Direct reporting to supervisors, HR, or the compliance officer.
      • Anonymous submissions through internal reporting platforms.

      All reports will be handled with strict confidentiality and impartiality, and appropriate actions will be taken to address confirmed violations.

   6. Books and Records and Internal Controls
      • Accurate and Transparent Record Keeping
        At Alghanim Healthcare (AHC), we are committed to maintaining accurate, transparent, and fair records of all business transactions, ensuring compliance with applicable laws and internal policies. Our financial records are maintained with the highest level of integrity and detail, reflecting the true nature of our operations and financial activities.

        We have established a strong system of internal controls to prevent, detect, and address any potential violations of our policies or regulatory requirements. Under no circumstances shall false, misleading, or artificial entries be made in our books and records. Every payment, transaction, and financial recordregardless of valuemust be documented with precision and accuracy to uphold our commitment to ethical business practices.

      • Expense Reporting and Accountability
        All expenses incurred by Alghanim Healthcare employees, contractors, and representatives must be:
        • Fully documented with a clear and detailed description of the purpose of the expense.
        • Supported by valid, original receipts or invoices that accurately reflect the amounts incurred.
        • Submitted and recorded in strict compliance with AHC’s Travel & Expense Policy and applicable financial guidelines.

      The submission or acceptance of false, incomplete, or misleading receipts and invoices is strictly prohibited, and any attempt to manipulate financial records will result in disciplinary action, including potential legal consequences.
      

      We expect all AHC personnel to exercise utmost diligence and responsibility in maintaining financial integrity and complying with our internal financial controls, ensuring that all transactions support our mission of transparency and accountability. For any inquiries or clarifications related to expense reporting ordinarily record keeping, employees should consult the Finance or Compliance departments.

      For any inquiries or clarifications related to expense reporting and financial record-keeping, employees should consult the Finance or Compliance departments.

   7. Compliance and Enforcement
      AHC enforces strict compliance with this policy through:
      • Regular training programs to educate employees and partners on anti corruption measures.
      • Periodic audits and compliance checks to identify and mitigate risks.
      • Strict disciplinary actions, including termination and legal proceedings, against violations of this policy.

Corporate Social Responsibility and Ethical Commitment

At AHC, we recognize our role in contributing to the well being of the communities we serve. Our ethical commitment extends beyond compliance to fostering a culture of integrity, responsibility, and respect, ensuring that our business operations contribute positively to society and uphold Kuwait’s ethical business landscape.

Summary and Disclaimer

Alghanim Healthcare remains steadfast in its mission to provide trusted, high quality healthcare solutions while upholding the highest standards of integrity. We call on every employee, partner, and stakeholder to join us in maintaining our reputation as a responsible, ethical, and transparent healthcare leader in Kuwait and beyond.

For further details or inquiries regarding this policy, please contact the Compliance Office at compliance@alghanimhc.com.