Business Ethics & Anti-Corruption Policy in Scottsdale

Business ethics and anti-corruption policy are fundamental pillars for any reputable organization operating in today’s global marketplace. For companies in Scottsdale, Arizona, establishing and adhering to a robust framework that governs ethical conduct and prohibits corrupt practices is not just a legal requirement but a strategic imperative. Maiyam Group understands the critical importance of integrity in all business dealings. This policy outlines our commitment to upholding the highest ethical standards and preventing corruption in all its forms across our operations and supply chains.

In the dynamic landscape of international mineral trading, maintaining trust and transparency is paramount. Our commitment extends from our headquarters in DR Congo to our global partners and clients. This document serves as a guide for all employees, contractors, and partners associated with Maiyam Group, ensuring a unified approach to ethical business conduct. We believe that a strong ethical foundation fosters long-term sustainability, builds stakeholder confidence, and contributes to a more just and equitable business environment worldwide, including within Scottsdale’s business community.

Understanding Business Ethics

Business ethics refers to the moral principles and values that guide the behavior and decision-making of individuals and organizations within the business world. It encompasses a broad range of issues, including fairness, honesty, responsibility, respect, and integrity. Ethical businesses strive to operate not only in compliance with laws and regulations but also in a manner that aligns with societal values and stakeholder expectations. This involves considering the impact of business decisions on employees, customers, suppliers, the community, and the environment.

Maiyam Group is committed to integrating ethical considerations into every facet of our operations. This means fostering a culture where employees are encouraged to act with integrity, even when faced with difficult choices. Our ethical framework guides our interactions, ensuring that we build trust and maintain long-term relationships based on mutual respect and fairness. We recognize that ethical conduct is not a static concept but an ongoing commitment that requires continuous evaluation and adaptation.

Core Principles of Business Ethics

At the heart of our ethical commitment are several core principles that guide our actions:

• Integrity: Acting honestly and transparently in all dealings.
• Accountability: Taking responsibility for our actions and decisions.
• Fairness: Treating all stakeholders equitably and without bias.
• Respect: Valuing diversity and upholding the dignity of every individual.
• Responsibility: Being mindful of our social and environmental impact.
• Compliance: Adhering to all applicable laws, regulations, and industry standards.

These principles form the foundation of our corporate culture and are embedded in our daily operations, from sourcing minerals to engaging with clients and partners. For our operations impacting or involving Scottsdale, these principles ensure a consistent standard of excellence and trustworthiness.

The Importance of Ethical Practices

Ethical business practices are crucial for several reasons. Firstly, they build and maintain trust with customers, investors, employees, and the public. Trust is a valuable asset that can lead to increased customer loyalty, stronger partnerships, and a positive brand reputation. Secondly, ethical behavior helps in attracting and retaining top talent. Employees want to work for organizations they respect and whose values align with their own.

Thirdly, ethical companies are often more resilient and sustainable in the long run. By operating responsibly, they mitigate risks associated with legal disputes, regulatory sanctions, and reputational damage. A strong ethical compass guides companies through complex challenges, ensuring they make decisions that are not only profitable but also principled. This approach is vital for Maiyam Group as we navigate the complexities of the global mineral trade.

Understanding Anti-Corruption Measures

Corruption, in its various forms, poses a significant threat to businesses, economies, and societies. It includes bribery, extortion, fraud, embezzlement, and conflicts of interest, among others. An effective anti-corruption policy is designed to prevent, detect, and address these illicit activities, ensuring that business is conducted with integrity and transparency.

Maiyam Group is unequivocally committed to combating corruption. Our policy aims to create a zero-tolerance environment for any corrupt practices, ensuring that our operations in DR Congo and our interactions with global partners, including those in Scottsdale, are conducted with the highest degree of honesty and ethical rigor. We believe that fighting corruption is not only a legal obligation but a moral responsibility that upholds the principles of fair competition and sustainable development.

What Constitutes Corruption?

Corruption can manifest in numerous ways, often involving the abuse of entrusted power for private gain. Common forms include:

• Bribery: Offering, promising, giving, accepting, or soliciting an advantage (financial or otherwise) as an inducement or reward for performing or refraining from an official act. This includes facilitation payments, which are small payments made to expedite routine governmental actions.
• Extortion: The practice of obtaining something, especially money, through threats or force.
• Fraud: Deception intended to result in financial or personal gain.
• Embezzlement: Misappropriation or theft of funds placed in one’s trust or belonging to one’s employer.
• Conflicts of Interest: Situations where personal interests (financial, familial, etc.) interfere, or appear to interfere, with the impartiality of official duties or business decisions.
• Abuse of Influence: Using one’s position or connections improperly to gain an unfair advantage.

Our policy explicitly prohibits all such activities, ensuring clarity for all stakeholders.

Legal and Regulatory Frameworks

Numerous international and national laws govern anti-corruption efforts. Key examples include the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and various UN conventions against corruption. These laws often have extraterritorial reach, meaning they can apply to companies and individuals operating outside their home countries. Maiyam Group operates in compliance with all applicable anti-corruption laws in the jurisdictions where we do business, including those relevant to our partners in Scottsdale.

Understanding and adhering to these complex legal frameworks is essential. Our policy is designed to align with these requirements, providing clear guidance to prevent violations and manage associated risks effectively. We regularly review and update our compliance measures to reflect evolving legal standards and best practices.

Maiyam Group’s Business Ethics & Anti-Corruption Policy

Maiyam Group is dedicated to conducting business with the utmost integrity, adhering to stringent ethical standards, and maintaining a zero-tolerance policy towards corruption. Our policy is designed to ensure that all our operations, interactions, and partnerships reflect these core values, providing a clear framework for ethical conduct for our employees, contractors, and business associates, including those operating in or interacting with Scottsdale.

We believe that ethical conduct and robust anti-corruption measures are not merely compliance obligations but are integral to our identity as a leading DR Congo mineral trade company and essential for building sustainable, trust-based relationships with our global partners.

Our Commitment to Ethical Conduct

We are committed to:

• Operating with Honesty and Transparency: All business dealings will be conducted with integrity, ensuring open communication and truthful representation.
• Respecting Laws and Regulations: We will comply with all applicable laws, regulations, and international standards in every jurisdiction where we operate.
• Fair Competition: We will compete fairly and ethically, refraining from any practices that distort markets or create unfair advantages.
• Valuing Our People: We are committed to providing a safe, respectful, and fair working environment for all our employees, free from discrimination and harassment.
• Responsible Sourcing: We prioritize ethical sourcing of minerals, ensuring compliance with international standards and regulations concerning conflict minerals and human rights.
• Environmental Stewardship: We are committed to minimizing our environmental footprint and operating in an environmentally responsible manner.

Zero Tolerance for Corruption

Maiyam Group strictly prohibits any form of corruption, including bribery, extortion, fraud, and conflicts of interest. This prohibition applies to all employees, directors, officers, agents, consultants, and any other persons acting on our behalf.

• No Bribery: We will not offer, promise, give, accept, or solicit bribes or any improper advantages. This includes prohibiting facilitation payments, which are often disguised bribes.
• No Conflicts of Interest: Employees and associates must avoid situations where their personal interests could conflict with the interests of the company. Any potential conflict must be disclosed immediately.
• Accurate Record-Keeping: All financial transactions and business records must be maintained accurately and transparently, reflecting the true nature of the dealings.
• Gifts, Hospitality, and Expenses: While reasonable and appropriate gifts, hospitality, or expenses may be exchanged, they must be transparent, properly documented, and must not be intended to improperly influence business decisions. Guidelines are provided separately.

Reporting Concerns and Non-Retaliation

We encourage all employees and associates to report any suspected violations of this policy or unethical behavior promptly. We have established clear channels for reporting, including:

• Reporting to your direct supervisor or manager.
• Contacting the HR department.
• Using our confidential whistleblowing hotline (details available internally).

Maiyam Group strictly prohibits retaliation against any individual who, in good faith, reports a concern or participates in an investigation. Such reports will be treated with the utmost confidentiality, and appropriate action will be taken.

Training and Awareness

Regular training programs will be conducted to ensure all employees and relevant associates understand this policy, their responsibilities, and the potential consequences of non-compliance. Promoting awareness is key to fostering a culture of integrity and ethical conduct throughout the organization.

Implementing the Policy in Practice

A robust policy is only effective if it is consistently implemented and enforced across all levels of the organization. Maiyam Group ensures that our Business Ethics & Anti-Corruption Policy is not just a document but a living framework that guides our daily operations and strategic decisions. This implementation strategy involves clear communication, ongoing training, diligent oversight, and accountability mechanisms.

For our operations and partnerships, including those connected to Scottsdale, this practical implementation ensures that our commitment to integrity is evident in every transaction and interaction. We strive to embed these principles into the fabric of our corporate culture, making ethical conduct the standard, not the exception.

Due Diligence on Third Parties

Given our role as a premier dealer in strategic minerals and commodities, we engage with a wide network of suppliers, agents, distributors, and other business partners. Maiyam Group conducts thorough due diligence on all third parties with whom we do business. This process involves:

• Risk Assessment: Evaluating the potential risks associated with each third party, considering their geographic location, industry, type of service provided, and reputation.
• Background Checks: Verifying the legitimacy of the business, checking for any history of corruption, sanctions, or adverse media coverage.
• Contractual Safeguards: Including specific clauses in contracts that require compliance with our ethical standards and anti-corruption policy, and allow for termination in case of violations.
• Ongoing Monitoring: Periodically reviewing the performance and conduct of third parties to ensure continued compliance.

This rigorous approach helps mitigate the risk of indirect involvement in corrupt activities through our business partners.

Record-Keeping and Financial Controls

Accurate and transparent financial records are essential for preventing and detecting corruption. Maiyam Group maintains robust accounting and internal control systems designed to:

• Ensure all transactions are properly authorized, recorded, and reflected accurately in our books and records.
• Prevent the creation of off-the-books funds or assets.
• Provide clear audit trails for all financial activities.
• Facilitate internal and external audits to verify compliance.

These controls help ensure that company funds are used appropriately and that no payments are made for illicit purposes.

Internal Controls and Audits

We implement a system of internal controls designed to safeguard company assets, ensure the accuracy of financial information, and promote operational efficiency. These controls include segregation of duties, authorization procedures, and regular reviews of financial and operational activities. Internal and external audits are conducted periodically to assess the effectiveness of these controls and identify any areas for improvement. These audits help ensure that our policies, including the anti-corruption policy, are being followed effectively across all operations.

Whistleblower Protection

A critical component of our anti-corruption strategy is our whistleblower protection mechanism. We understand that employees and associates may be hesitant to report concerns for fear of reprisal. Our policy guarantees that any individual reporting a concern in good faith will be protected from retaliation. Confidential reporting channels are available, ensuring that sensitive information is handled appropriately and investigations are conducted impartially. This encourages open communication and helps us identify and address potential issues proactively.

Training and Awareness Programs

Effective implementation of our Business Ethics & Anti-Corruption Policy hinges on ensuring that every individual associated with Maiyam Group understands their role and responsibilities. To achieve this, we invest significantly in comprehensive training and ongoing awareness programs tailored to different levels and functions within the company.

These programs are crucial for fostering a culture of integrity and ethical decision-making, ensuring that our commitment resonates from our DR Congo operations to our interactions with partners in Scottsdale and beyond. Our approach to training focuses on practical application and continuous reinforcement.

Mandatory Employee Training

All employees, from senior management to operational staff, are required to complete regular training on our Business Ethics & Anti-Corruption Policy. This training covers:

• Policy Overview: A detailed explanation of the policy’s objectives, scope, and key provisions.
• Identifying Red Flags: Recognizing common indicators of potential corruption, such as unusual payment requests, overly generous gifts, or pressure to bypass procedures.
• Reporting Procedures: Clear guidance on how and when to report concerns, emphasizing the whistleblower protection measures in place.
• Consequences of Violation: Understanding the serious disciplinary actions, including termination, and potential legal penalties for policy breaches.
• Case Studies and Scenarios: Practical examples relevant to our industry (mining and mineral trading) to illustrate how the policy applies in real-world situations.

Training is delivered through various methods, including online modules, in-person workshops, and team briefings, ensuring accessibility and engagement.

Specialized Training for High-Risk Roles

Employees in roles that involve higher risks of encountering corruption, such as those in procurement, sales, finance, and international business development, receive specialized, more intensive training. This may include modules on:

• Third-Party Due Diligence: Detailed procedures for vetting suppliers, agents, and other business partners.
• Anti-Bribery Best Practices: Specific guidance on navigating interactions with government officials and managing business development activities.
• International Regulations: In-depth understanding of laws like the FCPA and UK Bribery Act.

This targeted training equips individuals in critical positions with the specific knowledge and tools needed to mitigate risks effectively.

Promoting an Ethical Culture

Beyond formal training, we actively promote an ethical culture through various means:

• Leadership Commitment: Senior management consistently communicates the importance of ethics and integrity, setting the tone from the top.
• Internal Communications: Regular newsletters, intranet articles, and posters reinforce ethical messages and policy updates.
• Ethics Awareness Campaigns: Periodic campaigns focus on specific ethical themes, encouraging dialogue and reflection among employees.
• Integration into Performance Management: Ethical conduct is considered as part of employee performance evaluations, reinforcing its importance in day-to-day work.

By combining comprehensive training with continuous reinforcement of ethical values, Maiyam Group aims to foster a workplace where integrity is deeply ingrained and corruption has no place.

Compliance and Enforcement in Scottsdale and Globally (2026)

Maiyam Group’s commitment to business ethics and anti-corruption extends across all our global operations, ensuring that our standards are upheld consistently, whether in our home base in DR Congo or in our interactions with partners in Scottsdale, Arizona. In 2026, maintaining robust compliance and enforcement mechanisms is more critical than ever, given the increasing regulatory scrutiny and the evolving landscape of international business.

Our approach to compliance and enforcement is proactive, comprehensive, and integrated into our overall business strategy. We believe that clear policies, rigorous oversight, and appropriate consequences for violations are essential for preserving our reputation and ensuring sustainable growth.

Monitoring and Auditing

To ensure adherence to our Business Ethics & Anti-Corruption Policy, we conduct regular monitoring and auditing of our operations and business relationships. This includes:

• Internal Audits: Our internal audit team periodically reviews compliance with the policy, focusing on high-risk areas such as procurement, sales, and financial transactions.
• External Audits: Independent external auditors may be engaged to provide an objective assessment of our compliance program and financial controls.
• Compliance Reviews: Specific reviews may be conducted on third-party relationships, especially those identified as having higher risk profiles.

These audits and reviews help us identify potential weaknesses in our controls and ensure that our policies are being effectively implemented.

Investigation and Disciplinary Action

When potential violations of the policy are reported or detected, Maiyam Group initiates prompt and thorough investigations. These investigations are conducted impartially, respecting confidentiality and whistleblower protections. Based on the findings of an investigation:

• Disciplinary Measures: Appropriate disciplinary action will be taken against individuals found to have violated the policy. This may range from warnings and mandatory retraining to termination of employment or contract, depending on the severity of the violation.
• Remedial Actions: We will take necessary steps to address any weaknesses in our systems or controls that may have contributed to the violation, implementing corrective actions to prevent recurrence.
• Legal Action: In cases of serious violations, particularly those involving criminal activity, we will cooperate fully with relevant law enforcement authorities and may pursue civil remedies to recover losses.

Our commitment to enforcement ensures that violations are addressed seriously and consistently, reinforcing the message that unethical behavior will not be tolerated.

Continuous Improvement

The landscape of business ethics and anti-corruption is constantly evolving, with new regulations, emerging risks, and evolving best practices. Maiyam Group is committed to the continuous improvement of our compliance program. This involves:

• Regular Policy Review: Periodically reviewing and updating our Business Ethics & Anti-Corruption Policy to reflect changes in laws, regulations, and business operations.
• Staying Informed: Monitoring developments in anti-corruption enforcement and compliance trends globally.
• Feedback Mechanisms: Encouraging feedback from employees and stakeholders on the effectiveness of our policy and compliance programs.
• Benchmarking: Comparing our practices against industry standards and best practices to identify opportunities for enhancement.

By maintaining a dynamic and adaptive compliance framework, we ensure that our commitment to integrity remains robust and effective in 2026 and beyond, safeguarding our business and our reputation across all jurisdictions, including our valued connections in Scottsdale.

Scope and Application of the Policy

Maiyam Group’s Business Ethics & Anti-Corruption Policy is comprehensive in its scope, applying universally across all levels of our organization and extending to all individuals and entities acting on our behalf. This ensures a consistent and unwavering commitment to integrity, regardless of location or role.

The policy is designed to cover every aspect of our business, from raw material sourcing in DR Congo to logistical operations, financial transactions, and client engagements worldwide, including interactions relevant to Scottsdale, Arizona. Understanding the broad application of this policy is crucial for fostering a unified ethical culture.

Who the Policy Applies To

This policy applies to:

• All Employees: Including full-time, part-time, temporary, and contract employees at all levels of the organization.
• Directors and Officers: All members of the Board and executive management.
• Third Parties: Any individual or entity acting on behalf of Maiyam Group, including agents, consultants, distributors, suppliers, joint venture partners, and subcontractors.

All individuals and entities covered by this policy are expected to read, understand, and comply with its provisions.

Geographic Reach

The policy has global reach, applicable to all business activities conducted by Maiyam Group anywhere in the world. This includes operations in the Democratic Republic of Congo, any other country where we may operate or have business interests, and any interactions with international clients, partners, or governmental bodies, irrespective of their location. This global application ensures that our standards are consistently maintained, providing a reliable framework for business dealings in diverse regulatory environments, such as those encountered when engaging with businesses in Scottsdale.

Application to Specific Business Areas

Our policy is specifically applied to key business functions and areas prone to ethical risks:

• Procurement and Supply Chain: Ensuring ethical sourcing, fair bidding processes, and prohibiting bribery or conflicts of interest when selecting and managing suppliers.
• Sales and Marketing: Maintaining honesty in representations, avoiding deceptive practices, and prohibiting bribery or improper inducements to secure business.
• Financial Transactions: Ensuring accuracy in record-keeping, proper authorization for payments, and preventing fraud or embezzlement.
• Interactions with Government Officials: Strict adherence to rules regarding gifts, hospitality, facilitation payments, and engagement with public officials to avoid any appearance or act of corruption.
• Human Resources: Ensuring fair employment practices, preventing discrimination, and maintaining a respectful workplace free from harassment.

By clearly defining the scope and application, we aim to embed ethical considerations into every decision and action, reinforcing our commitment to integrity across the entire organization.

Frequently Asked Questions About Business Ethics & Anti-Corruption

Conclusion: Upholding Integrity in Global Business

Maiyam Group’s Business Ethics & Anti-Corruption Policy is more than just a set of rules; it is a reflection of our core values and our unwavering commitment to conducting business with integrity. By adhering to principles of honesty, transparency, fairness, and accountability, we aim to build lasting trust with our stakeholders, foster fair competition, and contribute positively to the global economy. Our comprehensive approach, encompassing clear policies, rigorous due diligence, continuous training, and robust enforcement mechanisms, ensures that ethical conduct is embedded in every aspect of our operations.

Whether operating in the Democratic Republic of Congo, engaging with partners in Scottsdale, Arizona, or interacting with clients worldwide, our dedication to ethical practices remains constant. We believe that upholding these standards is not only crucial for legal compliance and risk mitigation but is fundamental to our long-term success and sustainability as a premier mineral trading company. By fostering a culture of integrity and empowering our employees and partners to act ethically, we aim to set a benchmark for responsible business conduct in the industry in 2026 and beyond. Our commitment is to be a trusted partner, driven by ethical principles in all our endeavors.

Key Takeaways:

• Maiyam Group has a zero-tolerance policy for corruption, including bribery and conflicts of interest.
• The policy applies globally to all employees, directors, officers, and third parties acting on the company’s behalf.
• Rigorous due diligence, training, and internal controls are key to policy implementation.
• Whistleblower protection is guaranteed to encourage reporting of suspected violations.
• Upholding strong business ethics builds trust, enhances reputation, and ensures sustainable growth.