Anti-Bribery and Corruption Policy

IEC has a zero-tolerance approach to bribery, corruption, fraud and other improper business practices. We do not offer, promise, give, request, accept or authorise bribes or improper advantages in connection with our services or business activities.

We comply with all applicable anti-bribery and anti-corruption laws in the countries where we operate, including the UK Bribery Act 2010 and relevant laws and regulations in the United Arab Emirates.

This policy aims to:

• Prevent bribery and corruption within IEC's operations
• Establish clear standards of professional conduct
• Help employees and business partners recognise and avoid improper practices
• Protect students, families, educational institutions and other stakeholders
• Provide a safe process for reporting suspected violations
• Protect IEC's reputation and maintain trust in our services

This policy applies to everyone working for or representing IEC, including:

• Directors and managers
• Employees and temporary workers
• Tutors, mentors and consultants
• Agents and representatives
• Contractors and service providers
• Recruitment partners and introducers
• Educational and institutional partners
• Any other person or organisation acting on IEC's behalf

We expect our business partners to maintain anti-bribery and ethical standards consistent with this policy.

Bribery means offering, promising, giving, requesting, receiving or accepting anything of value to influence a decision, obtain an improper advantage or encourage someone to perform their duties improperly.

A bribe may include:

• Cash or cash equivalents
• Gifts or expensive hospitality
• Unauthorised commissions or referral payments
• Discounts or fee reductions given for an improper purpose
• Employment, internships or educational opportunities
• Travel, accommodation or entertainment
• Charitable or political contributions
• Personal favours
• Any other financial or non-financial benefit

A bribe does not need to be accepted or successful to constitute a violation. Offering, promising or requesting an improper benefit may itself be prohibited.

No person acting for or on behalf of IEC may:

• Offer or give a bribe to any individual, organisation or public official
• Request or accept a bribe or improper personal benefit
• Make unofficial payments to influence admission, scholarship, examination, visa or immigration decisions
• Provide false information or documents to obtain an improper advantage
• Pay undisclosed commissions, referral fees or kickbacks
• Use a third party to make a payment or take an action that IEC could not lawfully undertake directly
• Conceal an improper payment through false invoices, expenses or accounting records
• Retaliate against anyone who reports a concern honestly
• Ignore warning signs suggesting that bribery or corruption may be taking place

IEC cannot guarantee admission, scholarships, examination results or visa approvals through unofficial influence or payment. Such decisions remain entirely with the relevant universities, institutions, examination bodies, embassies and government authorities.

Facilitation payments are unofficial payments made to encourage or accelerate a routine action by a public official or another person.

IEC prohibits facilitation payments, regardless of their amount or whether they may be considered customary in a particular location.

Official fees paid directly to an authorised government body, embassy, university, examination provider or approved service centre are permitted, provided they are lawful, properly documented and supported by an official receipt.

If a payment is demanded because of an immediate and genuine threat to a person's health or safety, personal safety must take priority. The incident must be reported to IEC management as soon as it is safe to do so.

Reasonable and proportionate gifts or hospitality may be permitted when they:

• Have a legitimate business purpose
• Are lawful and appropriate
• Are modest in value
• Are offered openly rather than secretly
• Do not influence, or appear to influence, a business or official decision
• Are accurately recorded where required

Cash gifts and cash equivalents must never be offered or accepted.

Gifts or hospitality involving public officials, university decision-makers, admissions personnel, examination staff or visa officials require particular care and must receive prior approval from IEC management.

All commissions, referral fees and payments to agents, partners or introducers must:

• Be commercially reasonable
• Relate to genuine and lawful services
• Be approved by an authorised IEC representative
• Be supported by a written agreement or appropriate documentation
• Be paid through an approved and traceable method
• Be accurately recorded in IEC's financial records

IEC does not permit secret commissions, kickbacks or personal payments intended to influence professional decisions.

IEC will not make political contributions on behalf of the organisation unless they are lawful and formally authorised.

Charitable donations and sponsorships must not be used to disguise bribery or obtain an improper business advantage. They must be transparent, properly approved and accurately recorded.

Employees, representatives and business partners must avoid situations in which personal, financial or family interests conflict, or appear to conflict, with their responsibilities to IEC.

Any actual or potential conflict of interest must be disclosed promptly to IEC management. This includes personal relationships with applicants, suppliers, educational institutions, public officials or other parties who may influence a business decision.

IEC may conduct proportionate checks before appointing agents, consultants, recruitment partners, contractors or other third parties.

These checks may consider:

• The third party's ownership and reputation
• Qualifications and professional experience
• Previous allegations or evidence of misconduct
• Connections with public officials or decision-makers
• The reasonableness of proposed fees
• The services to be provided
• The proposed payment arrangements

IEC may refuse to appoint, suspend or terminate relationships with third parties that do not meet our ethical and compliance standards.

IEC maintains accurate books, records, invoices and supporting documents.

No person may create or approve:

• False, misleading or incomplete records
• Undisclosed accounts or funds
• Fictitious invoices
• Incorrect descriptions of payments
• Expenses without a genuine and documented business purpose

All payments must be authorised and recorded according to IEC's financial procedures.

Everyone covered by this policy is responsible for:

• Reading, understanding and following this policy
• Acting honestly and professionally
• Refusing improper payment requests
• Keeping accurate records
• Completing relevant training when requested
• Reporting suspected violations promptly
• Cooperating with any internal investigation

Managers have an additional responsibility to promote ethical conduct and respond appropriately to concerns.

Anyone who becomes aware of suspected bribery, corruption or unethical conduct connected with IEC should report it as soon as possible.

Concerns may be reported confidentially to:

• IEC Edu Consultancy
• Email: info@edu-consultancy.com
• Telephone/WhatsApp: +44 7442 978718
• Address: Ground Floor, 57th St, Al Garhoud, Dubai, United Arab Emirates

Reports should include as much relevant information as possible, such as the people involved, dates, communications, payments and supporting documents.

IEC will treat reports seriously and, where reasonably possible, confidentially. A person who raises a genuine concern in good faith will not be penalised or subjected to retaliation, even if the concern is ultimately not substantiated.

Deliberately making a false or malicious allegation may, however, result in appropriate action.

IEC may investigate any suspected violation fairly and confidentially. Everyone covered by this policy is expected to cooperate with an authorised investigation.

A breach of this policy may result in:

• Disciplinary action
• Termination of employment or engagement
• Termination of a contract or partnership
• Recovery of financial losses
• Reporting the matter to the relevant authorities
• Civil or criminal proceedings where appropriate

IEC may provide anti-bribery and ethical conduct training to employees, representatives and relevant business partners based on their responsibilities and level of risk.

This policy will be reviewed periodically and updated when necessary to reflect changes in IEC's operations, applicable laws or recognised compliance practices.

This Anti-Bribery and Corruption Policy has been approved by IEC's management and applies to all business activities conducted by or on behalf of IEC.