Anti-Corruption and Ethics Policy

1. Introduction

SK Teleco LLC is committed to conducting its business with integrity, transparency, and in full compliance with all applicable anti-corruption and anti-bribery laws, including but not limited to:

• The U.S. Foreign Corrupt Practices Act (FCPA)

• The UK Bribery Act 2010

• The United Nations Convention Against Corruption (UNCAC)

• The OECD Convention on Combating Bribery of Foreign Public Officials

This policy applies to all employees, officers, contractors, partners, and third parties representing or acting on behalf of SK Teleco LLC globally.

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2. Purpose of the Policy

The purpose of this policy is to:
✔ Prevent bribery, corruption, fraud, and unethical practices in SK Teleco's operations
✔ Ensure compliance with global anti-corruption standards
✔ Promote ethical business conduct across all business activities

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3. Scope of the Policy

This policy applies to:

• All SK Teleco LLC employees (full-time, part-time, contractors)

• Board members, executives, and officers

• Third-party agents, consultants, and intermediaries

• Any entity acting on behalf of SK Teleco LLC

 

4. Prohibited Conduct

SK Teleco LLC strictly prohibits:

• Offering, promising, giving, requesting, or accepting bribes or improper payments

• Providing anything of value to influence public officials or private entities inappropriately

• Making facilitation payments, unless legally required under written law

• Engaging in any form of corruption to secure business advantages

• Misusing company funds for illegal or unethical purposes

• Falsifying company records to conceal improper payments

 

5. Gifts, Hospitality, and Entertainment

Gifts, entertainment, or hospitality may be provided only if they are:
✔ Reasonable in value and frequency
✔ Provided transparently and with proper approvals
✔ Not intended to influence business decisions improperly
✔ Compliant with local laws and cultural norms

    Lavish, excessive, or concealed gifts or hospitality are strictly prohibited.

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6. Political Contributions and Charitable Donations

• SK Teleco LLC does not make political donations to influence business decisions

• Charitable contributions must be legitimate, documented, and not serve as a cover for bribery.

 

7. Third-Party Risk Management

• Due diligence is required before engaging agents, consultants, or partners

• Contracts must include anti-corruption obligations for third parties

• SK Teleco LLC may terminate relationships with third parties violating this policy

 

8. Compliance with International Standards

SK Teleco LLC adheres to:
✔ The UN Convention Against Corruption
✔ The OECD Anti-Bribery Convention
✔ All applicable anti-corruption laws in jurisdictions where SK Teleco operates

 

9. Reporting Violations

• Employees and third parties must report suspected violations promptly

• Reports can be made to supervisors, the Managing Member, or through designated compliance channels

• Whistleblowers will be protected from retaliation

 

10. Disciplinary Action

Violations of this policy may result in:
✔ Disciplinary measures, including termination of employment
✔ Termination of contracts with third parties
✔ Legal action and reporting to authorities

 

11. Training and Awareness

SK Teleco LLC will:

• Provide regular anti-corruption training for employees and relevant third parties

• Raise awareness of ethical standards and reporting obligations

 

12. Review and Updates

This policy will be reviewed annually and updated as necessary to ensure alignment with legal developments and best practices.

 

13. Certification

All employees and third parties representing SK Teleco LLC must acknowledge and comply with this policy