Anti Bribery and Corruption Policy

Bribery is defined as the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action. It is illegal and constitutes a breach of trust. A bribe may be offered or provided to gain a commercial, contractual, regulatory, or personal advantage.

Bribery and corruption are prohibited under multiple international laws and regulations, and FIDI requires its affiliates to maintain proactive measures to prevent, detect, and report such conduct.

Orbit will not tolerate bribery, corruption, or attempted bribery in any form. This applies equally to offering or accepting a bribe, whether directly or through third parties. These practices are incompatible with FIDI’s core values of conducting business to the highest legal, moral, and ethical standards.

In accordance with the FIDI Anti-Bribery and Anti-Corruption Charter, Orbit and all associated parties must adhere to the following principles:

• Never engage in any form of bribery, whether directly or through any third party.
• Never offer, make, or authorize an improper payment or authorize an improper payment (cash or otherwise) to any individual, including any local or foreign public official, anywhere in the world.
• Never attempt to induce any individual or public official to act illegally or improperly.
• Never offer or accept money or anything of value, such as gifts, kickbacks, or commissions, in connection with obtaining business or awarding contracts.
• Never offer gifts or hospitality to public employees or government officials where any expectation or implication of a return favour exists.
• Never accept gifts from business partners where a return favour is expected or implied.
• Never facilitate payments to obtain services to which one is not normally entitled.
• Never disregard or fail to report any indication of improper payments to the appropriate authorities.
• Never induce or assist another individual to violate any applicable law or regulation.

These commitments apply to all Orbit employees, agents, suppliers, consultants, and any other persons or entities acting on behalf of Orbit.

Orbit ensures awareness of, and compliance with, all applicable anti-bribery, anti-corruption, and competition laws in the jurisdictions in which it operates. This includes laws governing international business conduct, such as those addressing corruption and anti-competitive practices.

Orbit expects all business partners, contractors, and associated third parties to uphold standards equivalent to those set out in this policy and in the FIDI Charters. Orbit monitors compliance and expects cooperation in maintaining ethical, transparent, and lawful business relationships.