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Global Anti-Corruption Policy

Effective: January 1, 2025

Executive Summary

Agallas Equities is firmly committed to preventing bribery, both within the Dominican Republic and abroad. Agallas Equities has implemented a Global Anti-Corruption Policy (“Anti-Corruption Policy”) to ensure that all employees act in compliance with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and local regulations.

Agallas Equities’ Anti-Corruption Policy:

  • Reaffirms our commitment to preventing bribery in all forms, whether direct or indirect, in both the private and public sectors.
  • Mandates anti-corruption training for all employees, with specialized training for those in roles that carry inherent corruption risks.

  • Provides clear guidelines for reporting corruption-related concerns.

  • Requires accurate maintenance of financial records to ensure transparency.

  • Prohibits employees from giving or receiving cash or cash equivalents in any form.
  • Establishes documented procedures for giving anything of value to external parties, ensuring that such actions are reasonable, customary, and proportionate to the related business purposes.

  • Sets pre-clearance thresholds for business hospitality, gifts, charitable contributions, sponsorships, political contributions, and referred candidates.

  • Requires employees to report business hospitality or gifts received from external parties.
  • Prohibits facilitation payments in all business dealings.
  • Establishes a system of compliance controls when hiring third parties that may pose corruption risks to the firm.

Compliance with anti-corruption laws is essential for Agallas Equities, protecting the company and its investors from the risks and damages associated with corrupt practices.

Disclaimer
This website is neither an offer to sell nor a solicitation of an offer to purchase shares of any security offered by Agallas Equities. Such securities are offered only by means of a prospectus or offering memorandum. This material must be read in conjunction with a prospectus in order to understand fully all of the implications and risks of an investment in the securities offered by Agallas Equities LLC. Neither the Securities and Exchange Commission, the Attorney General of the State of New York nor any other state securities regulator has passed on or endorsed the merits of the securities offered by Agallas Equities LLC. Any representation to the contrary is unlawful.