Anti-Bribery & Anti-Corruption Policy

We conduct business honestly and without bribery, kickbacks, secret commissions or improper influence. This applies to dealings with public officials and with private parties alike.

This policy applies to all personnel, contractors, agents, introducers and any party acting for or on behalf of GCI.

We design our conduct to comply with the foreign bribery and corruption provisions of the Australian Criminal Code, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and equivalent laws in the countries where we operate.

These laws can apply extraterritorially. Conduct that is tolerated locally may still be a serious criminal offence for us and for our counterparties.

• Offering, promising, giving, requesting, agreeing to receive or accepting any financial or other advantage to induce or reward improper performance.
• Payments to secure permits, licences, customs clearance, export approval or favourable treatment outside the lawful, documented process.
• Kickbacks, secret commissions or undisclosed benefits to employees or agents of a counterparty.
• Political donations or charitable contributions made to obtain a business advantage.
• Using an intermediary, consultant or introducer to do indirectly what this policy forbids directly.
• Concealing or misdescribing any payment in records or invoices.

Facilitation or "grease" payments to expedite routine government action are prohibited without exception, including where locally customary.

The only exception is a genuine safety exception: where a person's life, limb or liberty is under immediate threat, payment may be made to remove that threat. It must be reported to the Director as soon as possible and recorded accurately.

Modest, infrequent and transparent business hospitality is acceptable where it is proportionate, given openly, not intended to influence a decision, lawful in the recipient's jurisdiction, and accurately recorded.

Cash or cash equivalents must never be given or accepted. Anything of more than nominal value requires prior approval from the Director, and gifts to public officials require approval in every case.

Third parties acting for GCI are subject to corruption-risk due diligence before appointment, must be paid a documented, commercially justified fee for genuine services, and must contractually commit to anti-bribery obligations with audit and termination rights.

Success fees payable to a party whose only value is access to officials will not be agreed. We do not pay commissions into accounts in jurisdictions unrelated to the services performed.

• Requests for payment to a personal account, a third party or an unrelated jurisdiction.
• Unusual commission rates or fees with no clear deliverable.
• A counterparty insisting on a specific agent, official or "expediter".
• Reluctance to sign anti-bribery warranties or to allow documentation of a payment.
• Invoices that are vague, backdated or lacking supporting evidence.

All payments must be accurately described, supported by documentation and recorded in our books. No off-book accounts, false invoices or misleading descriptions are permitted.

Our agreements include anti-bribery warranties and termination rights for breach.

Personnel and counterparties must report suspected bribery or corruption to the Director at goldcapitalinternational@gmail.com. Reports may be made confidentially.

We do not tolerate retaliation against anyone who reports a concern in good faith, and no one will suffer commercial detriment for refusing to pay or accept a bribe, even if that costs GCI business.

Breach may result in termination of employment, engagement or contract, and referral to law enforcement. Individuals and companies can face substantial fines and imprisonment.

The Director owns this policy and reviews it at least annually with input from qualified legal counsel.