Anti-Bribery & Anti-Corruption Policy

1. Statement of zero tolerance

Harker International (Pvt) Ltd (Reg. No. PV 00338032), Kandy, Sri Lanka, which operates SriLankaExport.com (the “Platform”), conducts business honestly and without bribery, corruption, or facilitation payments of any kind. We have zero tolerance for bribery and corruption involving our employees, the Platform’s Vendors and Buyers, or anyone acting for us.

This Policy applies to all employees, directors, officers, vendors, buyers, agents, intermediaries, and any party acting on behalf of Harker International or transacting through the Platform.

2. Laws we comply with and require compliance with

Through Harker International’s domicile and the Platform’s international reach, this Policy is aligned with the following anti-bribery and anti-corruption laws. Where a Buyer’s or Vendor’s home jurisdiction imposes additional or stricter obligations, those obligations apply in addition to this Policy.

3. What is prohibited

You may not, directly or indirectly, offer, promise, give, request, agree to receive, or accept:

• Any payment, gift, hospitality, or benefit intended to induce or reward the improper performance of a function or activity, whether the recipient is a public official, a private-sector counterparty, or any other person.
• Any payment to a public official (or any person at the request of a public official) to expedite or secure routine governmental action, including customs clearance, license issuance, or inspection, commonly known as “facilitation payments.” Facilitation payments are prohibited under UK Bribery Act 2010 and discouraged under FCPA; we prohibit them in all cases.
• Any kickback, secret commission, or undisclosed referral fee arising from a transaction conducted through the Platform.
• Any payment through a third party (an “intermediary”) where you know or have reason to suspect the payment will result in conduct prohibited by this Policy.

4. Gifts and hospitality

Modest, occasional, transparent gifts and hospitality given in the course of legitimate business are permitted, subject to the following limits:

• Reasonable in value (as a guideline, single instances under USD 100, aggregate per recipient per calendar year under USD 250). Higher thresholds may apply where local custom and reasonable business practice support them; document the rationale.
• Given openly, not concealed.
• Not in cash or cash equivalents.
• Not given to a public official where this would be unlawful in the recipient’s jurisdiction.
• Not connected to a specific decision or transaction in a way that could appear to influence it.
• Recorded in the relevant party’s books.

5. Political contributions and charitable donations

Harker International does not make political contributions in any jurisdiction. Charitable donations are permitted where they are lawful, transparent, made to bona fide charities, not directed by a counterparty in connection with a transaction, and properly recorded.

6. Third-party due diligence

Where Harker International engages an agent, broker, distributor, freight forwarder, customs clearance partner, or other third party who interacts with public officials or commercial counterparties on its behalf, we conduct risk-based due diligence. The level of diligence reflects the country, sector, and transaction risk. Engagements include written anti-bribery undertakings, audit rights, and termination rights for breach.

7. Books, records, and internal controls

All payments processed through the Platform are recorded accurately, in reasonable detail, and in a manner that fairly reflects the underlying transactions, in line with Sri Lankan accounting standards and the recordkeeping provisions of the FCPA. No off-book accounts, undisclosed funds, or inadequately documented transactions are permitted.

8. Vendor and Buyer obligations

By listing on or transacting through SriLankaExport.com, Vendors and Buyers represent and warrant that:

• They will comply with the anti-bribery and anti-corruption laws of every jurisdiction relevant to their business, including this Policy.
• They have not, and will not, offer or accept any prohibited payment in connection with their use of the Platform.
• Their officers, employees, agents, and intermediaries are bound by anti-bribery commitments equivalent to this Policy.
• They will cooperate with reasonable Harker International inquiries into compliance with this Policy.
• They will promptly report suspected breaches through the channels described in section 10.

9. Red flags

Examples of situations that require escalation under section 10 before proceeding:

• Requests for payment to be made to a country, bank, or account unrelated to the transaction.
• Requests for invoices that do not match the goods or services actually provided.
• Requests for unusually high “commissions,” “consultancy fees,” or “success fees.”
• A counterparty’s insistence on engaging a specific agent or intermediary without business justification.
• Demands for cash payments, payments in advance of services rendered, or payments to a person other than the counterparty.
• Refusal to provide written anti-bribery undertakings or to sign standard contractual provisions.

10. Reporting concerns

Suspected breaches of this Policy must be reported promptly. Reports can be made:

• To info@harker.international with subject “ABC concern.”
• Through the protected channels described in the Whistleblower & Speak-Up Policy, including anonymous routes.

Reports made in good faith are protected from retaliation under our Whistleblower Policy. Knowingly false reports are themselves a breach of this Policy.

11. Enforcement and consequences

Confirmed breaches result in:

• For employees: disciplinary action up to and including dismissal.
• For Vendors: account suspension or termination, removal of listings, withholding of payouts pending investigation, and where applicable, referral to law-enforcement authorities. See Vendor Agreement §14.
• For Buyers: account suspension or termination and refusal of further transactions.
• For any party: referral to the Commission to Investigate Allegations of Bribery or Corruption (CIABOC) in Sri Lanka, or to the equivalent authority in any other relevant jurisdiction.

12. Training and review

Harker International employees with material exposure to public officials, freight forwarders, customs clearance, or third-party intermediaries receive anti-bribery training on appointment and refresher training annually. This Policy is reviewed at least annually by the Managing Director and Executive Director. The next scheduled review is May 2027.