Sustainable Anti-Corruption Policy

Context and Sustainability Commitment

Nepal Hiking Team is a responsible trekking and tour operator committed to contributing positively to the environment, culture, economy, and society. Environmental conservation, social responsibility, ethical business conduct, and the promotion of sustainable tourism are integral to our company’s principles, professional activities, and management practices.

We aim to contribute to sustainable development and support our clients in travelling responsibly. We therefore follow and promote responsible business practices that reduce the environmental and social impacts of our activities and encourage our clients, suppliers, partners, and other stakeholders to adopt similar practices.

Ethical and transparent business conduct is an essential part of our sustainability commitment. Nepal Hiking Team does not tolerate corruption, bribery, fraud, or other forms of unethical business conduct.

Purpose

The purpose of this Anti-Corruption and Bribery Policy is to protect the integrity and ethical standards of Nepal Hiking Team by preventing and prohibiting corruption, bribery, and related misconduct.

This policy establishes clear expectations for employees and business partners and provides a framework for identifying, preventing, reporting, and addressing potential corruption risks. It supports transparent, lawful, fair, and responsible business practices in all of the company’s activities.

Scope

This policy applies to all employees, directors, management, guides, contractors, agents, representatives, suppliers, consultants, and other third parties acting for or on behalf of Nepal Hiking Team.

It applies to all business activities and professional relationships, including interactions with clients, suppliers, hotels, transport providers, guides, porters, local representatives, government officials, community representatives, business partners, and other stakeholders.

The policy applies regardless of the location or nature of the business activity.

Policy Commitment

Nepal Hiking Team maintains a zero-tolerance approach to bribery and corruption.

All employees, directors, management, and representatives are expected to act honestly, responsibly, transparently, and in the best interests of the company. No person acting on behalf of Nepal Hiking Team may offer, promise, give, request, or accept an improper advantage in order to influence a business decision or obtain an improper benefit.

Nepal Hiking Team is committed to complying with applicable laws and regulations relating to bribery, corruption, fraud, and ethical business conduct.

Definitions

Bribery: Offering, promising, giving, requesting, or accepting anything of value with the intention of improperly influencing a person’s actions, decisions, or judgment.

Corruption: The misuse of entrusted authority or position for private or improper benefit. This includes bribery, kickbacks, fraud, favoritism, and abuse of power.

Facilitation Payment: An unofficial payment made to a government official or other person to secure or speed up a routine governmental or administrative action.

Kickback: A payment, benefit, or other advantage improperly provided in return for influencing or rewarding a business decision or transaction.

Conflict of Interest: A situation in which an individual’s personal, financial, family, or other interests could improperly influence, or appear to influence, their professional judgment or decisions on behalf of the company.

Prohibited Conduct

No employee, director, management representative, contractor, agent, or other person acting on behalf of Nepal Hiking Team may engage in or facilitate the following:

Bribery

Offering, promising, giving, requesting, soliciting, or accepting any improper payment, benefit, gift, service, or other thing of value intended to influence a decision or obtain an improper business advantage is prohibited.

This applies to dealings with government officials, clients, suppliers, business partners, community representatives, and other stakeholders.

Facilitation Payments

Nepal Hiking Team prohibits facilitation payments made to government officials or other persons to expedite or secure routine governmental or administrative actions, including matters relating to permits, immigration, customs, inspections, or similar procedures.

Where an employee is pressured or threatened to make such a payment, the employee should prioritize personal safety and report the incident to management as soon as reasonably practicable.

Kickbacks

Employees and representatives must not offer, request, provide, or accept kickbacks or other improper benefits in connection with contracts, purchases, supplier selection, client services, or other business decisions.

Fraud and Falsification

Employees must not engage in deception, falsification, misappropriation, or other dishonest conduct intended to obtain financial or personal benefit or cause loss to the company or another party.

Political Contributions

Company funds, assets, facilities, or resources must not be used to make political contributions or provide improper political benefits on behalf of Nepal Hiking Team.

Donations and Sponsorships

Charitable donations, sponsorships, community contributions, and similar activities must have a legitimate purpose and must not be offered or provided in exchange for business advantages, preferential treatment, or other improper benefits.

Gifts, Hospitality and Entertainment

Gifts, meals, entertainment, travel, accommodation, hospitality, or other benefits must never be offered or accepted for the purpose of improperly influencing a business decision.

Any legitimate gift or hospitality must be:

• Connected to a legitimate business or professional purpose.
• Reasonable and proportionate in value and frequency.
• Appropriate to the circumstances and relationship.
• Provided without any expectation of an improper favor or business advantage.
• Never provided or accepted in cash or cash equivalents.
• Reported to management where required by company procedures or where there is uncertainty about its appropriateness.

Employees must decline any gift, hospitality, or benefit that could reasonably be perceived as an attempt to influence their professional judgment.

Conflicts of Interest

Employees must act in the best interests of Nepal Hiking Team and disclose any actual, potential, or perceived conflict of interest that could affect their professional judgment.

Particular care should be taken in relationships with hotels, transport providers, guides, porters, suppliers, local representatives, contractors, community representatives, and government officials.

Employees must not use their position with Nepal Hiking Team to obtain personal benefits or give preferential treatment to relatives, friends, or businesses in which they or their associates have a personal or financial interest.

Potential conflicts of interest must be disclosed to the employee’s direct supervisor, Sustainability Coordinator, or Managing Director as soon as reasonably practicable.

Supplier and Third-Party Conduct

Nepal Hiking Team expects suppliers, agents, contractors, consultants, local partners, and other third parties acting on its behalf to conduct business ethically and comply with applicable anti-corruption requirements.

Where appropriate and proportionate to the level of risk, Nepal Hiking Team will conduct reasonable due diligence before engaging relevant third parties and will communicate its expectations regarding ethical business conduct.

Supplier selection and purchasing decisions must be based on legitimate and transparent business considerations, including:

• Quality
• Price
• Safety
• Sustainability
• Reliability
• Service
• Relevant qualifications and experience

Employees must not receive personal payments, gifts, commissions, favors, or other benefits in exchange for selecting or continuing to use a particular supplier or service provider.

Where a third party is found to have engaged in serious corruption or bribery connected to Nepal Hiking Team’s activities, the company may take appropriate corrective action, including suspension or termination of the business relationship.

Accurate Records and Financial Controls

Nepal Hiking Team is committed to maintaining accurate, complete, and transparent financial and business records.

All financial transactions must be properly recorded and supported by appropriate documentation. No employee or representative may:

• Create or maintain undisclosed or off-book accounts.
• Falsify, alter, or conceal company records.
• Create or submit false invoices or supporting documents.
• Submit fictitious or misleading expenses.
• Misclassify payments or conceal their true purpose.
• Approve or process a payment that they know or reasonably suspect is improper.

Financial records and supporting documentation must be maintained in accordance with the company’s applicable financial procedures and legal requirements.

Reporting Concerns and Protection from Retaliation

Nepal Hiking Team encourages employees and other stakeholders to report suspected bribery, corruption, fraud, conflicts of interest, or other violations of this policy.

Reports may be made to the Sustainability Coordinator or Managing Director. Where reasonably practicable, concerns may be raised confidentially.

All reports will be treated appropriately and handled with due consideration for confidentiality, fairness, and the rights of those involved.

Nepal Hiking Team prohibits retaliation against any person who, in good faith:

• Reports suspected misconduct.
• Raises an ethical or compliance concern.
• Refuses to participate in bribery or other prohibited conduct.
• Cooperates with an investigation.

Knowingly making a false or malicious allegation is not protected under this provision and may result in appropriate disciplinary action.

Investigation and Corrective Action

Nepal Hiking Team will assess reported concerns and, where appropriate, conduct an investigation based on the nature and seriousness of the allegation.

Investigations will be handled fairly and confidentially to the extent reasonably practicable.

Where a violation is confirmed, Nepal Hiking Team will take appropriate corrective action. Depending on the circumstances, this may include additional training, internal controls, disciplinary action, termination of employment, suspension or termination of a supplier or third-party relationship, or referral to the appropriate authorities where required.

Training and Awareness

Nepal Hiking Team will promote awareness of this policy among employees and relevant business partners.

Where appropriate:

• New employees will receive anti-corruption awareness as part of their induction.
• Relevant employees will receive periodic training on corruption risks and ethical business conduct.
• Employees involved in higher-risk activities or decision-making will receive appropriate guidance.
• Management will communicate the company’s anti-corruption expectations to relevant suppliers and business partners.
• Records of relevant training and awareness activities will be maintained.

Roles and Responsibilities

Managing Director: Provides leadership and oversight, approves this policy, and supports its implementation throughout the company.

Sustainability Coordinator: Coordinates implementation, promotes awareness, monitors relevant risks, supports reporting and review processes, and recommends improvements where necessary.

Managers and Supervisors: Lead by example, communicate the requirements of this policy, support employees in raising concerns, and address identified risks within their areas of responsibility.

Employees and Representatives: Read, understand, and comply with this policy; avoid prohibited conduct; disclose conflicts of interest; and report suspected violations or concerns.

Suppliers and Third Parties: Conduct business ethically, comply with applicable requirements, and cooperate with reasonable anti-corruption expectations communicated by Nepal Hiking Team.

Monitoring and Continuous Improvement

Nepal Hiking Team will monitor the implementation of this policy as part of its broader sustainability and management practices.

Monitoring may include reviewing reported concerns, identifying corruption risks, assessing relevant supplier and third-party relationships, reviewing financial controls, maintaining training records, and evaluating the effectiveness of existing preventive measures.

Where weaknesses or risks are identified, Nepal Hiking Team will take appropriate corrective or preventive action and seek to continuously improve its anti-corruption practices.

Policy Review

This policy will be reviewed at least annually and may be reviewed earlier where there are significant changes in applicable legislation, business activities, identified risks, company procedures, or relevant sustainability and ethical business practices.

Any necessary amendments will be approved by the Managing Director and communicated to relevant employees and stakeholders.

Contact Information

For questions regarding this policy, guidance on a specific situation, or to report a potential concern, please contact:

Sustainability Coordinator

Aryan Thapa | Nepal Hiking Team

All concerns will be handled in accordance with this policy and the company’s applicable procedures.