Anti-Bribery, Human Trafficking & Forced Labour Policy
I A M IT Technologies LLC (IAMIT)
Effective Date: September 2026
Policy Owner: Management / Human Resources & Legal
Applies To: IAMIT employees, management, contractors, consultants, temporary workers, interns, suppliers, business partners and other third parties acting on behalf of IAMIT.
1. Our Commitment
I A M IT Technologies LLC ("IAMIT") is committed to conducting its business ethically, responsibly and with respect for internationally recognized human rights.
We maintain a zero-tolerance approach towards bribery, corruption, human trafficking, modern slavery, forced labour, child labour, exploitation and other practices that violate fundamental human rights.
This Policy forms part of IAMIT's broader commitment to responsible business practices, ethical conduct, employee welfare, legal compliance and responsible supply-chain management.
IAMIT expects the same standards from its employees, contractors, suppliers, consultants, business partners and other third parties associated with our business.
2. International Standards and Applicable Laws
IAMIT seeks to conduct its operations in accordance with applicable laws and internationally recognized principles relating to human rights, ethical employment and responsible business conduct.
Our approach is informed by internationally recognized standards, including:
- International Labour Organization (ILO) fundamental principles and standards relating to forced labour and child labour;
- ILO Forced Labour Convention, 1930 (No. 29);
- ILO Abolition of Forced Labour Convention, 1957 (No. 105);
- United Nations Guiding Principles on Business and Human Rights;
- Applicable anti-bribery and anti-corruption legislation in the jurisdictions in which IAMIT operates;
- Applicable employment, immigration, labour, health and safety and human-rights laws; and
- Other applicable local and international legal and regulatory requirements.
The ILO defines forced labour as work or service obtained under the threat of a penalty and without the person's voluntary consent.
Where local law provides a higher level of protection, IAMIT will seek to comply with the applicable legal requirement.
3. Scope
This Policy applies throughout IAMIT's operations and business relationships, including our activities and personnel in the United Arab Emirates, Qatar, Oman, India and other jurisdictions in which IAMIT operates or conducts business.
It applies to:
- Employees and management;
- Temporary and contract workers;
- Interns and trainees;
- Consultants and professional service providers;
- Recruitment agencies;
- Suppliers and subcontractors ;
- Business partners and representatives; and
- Other third parties acting for or on behalf of IAMIT.
4. Human Trafficking and Modern Slavery
IAMIT strictly prohibits all forms of human trafficking and modern slavery.
This includes, but is not limited to:
- Forced or compulsory labour;
- Debt bondage;
- Slavery and servitude;
- Human trafficking for labour exploitation;
- Coercive or deceptive recruitment;
- Exploitation of vulnerable workers;
- Involuntary labour;
- Forced or exploitative work arrangements; and
- Any practice intended to restrict a person's freedom to work or leave employment lawfully.
IAMIT will not knowingly engage with any individual, supplier or business partner involved in human trafficking or modern slavery.
5. Forced Labour
IAMIT believes that employment must be entered into freely and that workers must be treated with dignity and respect.
IAMIT prohibits:
- Threats, intimidation or physical coercion to obtain or retain labour;
- Forced or involuntary employment;
- Debt bondage or recruitment-related debt used to compel work;
- Withholding wages to force continued employment;
- Unlawful restriction of freedom of movement;
- Retention or misuse of workers' identity documents for coercive purposes;
- Deceptive recruitment practices;
- Threats of unlawful retaliation;
- Forced overtime or work obtained through coercion; and
- Any other practice that may amount to forced labour.
Workers must be free to leave employment in accordance with applicable law and contractual notice requirements.
The ILO identifies coercion, threats, withholding wages or identity documents and restrictions on workers' freedom as indicators that may be relevant to forced labour risks.
6. Child Labour
IAMIT does not employ or knowingly engage in child labour.
All recruitment and employment practices must comply with applicable minimum-age requirements and child-labour laws in the relevant jurisdiction.
IAMIT expects suppliers, contractors and business partners to maintain equivalent standards and to take appropriate measures to prevent child labour within their operations and supply chains.
7. Fair and Ethical Employment
IAMIT is committed to maintaining a workplace where people are treated with dignity, fairness and respect.
We expect:
- Employment to be based on freely agreed terms;
- Fair and lawful compensation;
- Compliance with applicable working-hour requirements;
- Appropriate rest and leave entitlements;
- A safe and healthy working environment;
- Respectful treatment of employees;
- Freedom to raise workplace concerns;
- Protection against unlawful discrimination and harassment; and
- No retaliation against individuals who raise concerns in good faith.
8. Recruitment and Employment Agencies
IAMIT expects recruitment agencies and other labour intermediaries to operate ethically and in compliance with applicable laws.
Recruitment practices must not involve:
- False or misleading employment information;
- Recruitment fees or arrangements that unlawfully burden workers;
- Threats or coercion;
- Trafficking or exploitation;
- Retention of personal documents for coercive purposes; or
- Any other practice that restricts a worker's freedom or rights.
IAMIT may conduct appropriate due diligence on recruitment agencies and other labour providers before and during the business relationship.
9. Anti-Bribery and Anti-Corruption
IAMIT maintains a zero-tolerance approach to bribery and corruption.
No employee or third party acting on behalf of IAMIT may directly or indirectly offer, promise, authorize, request or accept an improper payment, benefit, gift or advantage intended to influence a business decision or obtain an improper advantage.
This includes:
- Bribes and kickbacks;
- Facilitation payments where prohibited by applicable law;
- Improper gifts or hospitality;
- Undisclosed commissions;
- Improper benefits to public officials or private-sector representatives;
- Fraudulent or misleading business practices; and
- Any other form of corrupt conduct.
All business transactions must be conducted transparently, accurately and in accordance with applicable laws and IAMIT policies.
10. Supplier and Business Partner Standards
IAMIT expects suppliers, subcontractors, consultants and business partners to uphold standards consistent with this Policy.
Where appropriate, IAMIT may assess third parties with respect to:
- Human-rights practices;
- Labour standards;
- Forced-labour and human-trafficking risks;
- Child-labour risks;
- Anti-bribery and anti-corruption controls;
- Employment practices;
- Health and safety;
- Ethical business conduct; and
- Compliance with applicable laws.
IAMIT may include appropriate contractual requirements relating to human rights, ethical conduct, anti-bribery, forced labour and human trafficking.
11. Due Diligence and Risk Assessment
IAMIT seeks to identify and address potential human-rights and ethical-business risks arising from its own operations and business relationships.
Depending on the nature and risk of the relationship, due diligence may include:
- Supplier and third-party screening;
- Review of relevant policies and certifications;
- Contractual compliance requirements;
- Employee and management awareness;
- Risk assessments;
- Periodic reviews;
- Investigation of reported concerns; and
- Corrective actions where issues are identified.
The UN Guiding Principles on Business and Human Rights recommend that businesses conduct human-rights due diligence to identify, prevent, mitigate and account for actual and potential adverse human-rights impacts.
12. Reporting Concerns
IAMIT encourages employees, suppliers, contractors, business partners and other stakeholders to report suspected violations of this Policy.
Concerns may include suspected:
- Bribery or corruption;
- Human trafficking;
- Forced or compulsory labour;
- Child labour;
- Exploitation;
- Coercive recruitment;
- Harassment or discrimination;
- Unethical conduct; or
- Other violations of applicable law or IAMIT policies.
Reports should be made through the appropriate IAMIT management, HR, Legal or designated reporting channel.
IAMIT will treat concerns seriously and will take appropriate steps to review and investigate reported matters.
13. Non-Retaliation
IAMIT does not tolerate retaliation against any person who raises a concern or reports a suspected violation in good faith.
Employees and other stakeholders are encouraged to raise concerns without fear of intimidation, discrimination or adverse treatment.
Where a concern is substantiated, IAMIT will take appropriate corrective or disciplinary action in accordance with applicable law and company procedures.
14. Training and Awareness
IAMIT promotes awareness of ethical business conduct, human rights, anti-bribery requirements and responsible employment practices.
Relevant employees and personnel may receive training or awareness sessions covering:
- Anti-bribery and anti-corruption;
- Human trafficking and modern slavery;
- Forced labour risks;
- Ethical recruitment;
- Supplier and third-party responsibilities;
- Reporting and escalation procedures; and
- Applicable legal and company requirements.
Training requirements may be reviewed periodically based on business activities, identified risks and applicable legal requirements.
15. Monitoring and Continuous Improvement
IAMIT is committed to continuously improving its approach to ethical business conduct and human-rights protection.
We may periodically review:
- Policy effectiveness;
- Compliance risks;
- Supplier and third-party relationships;
- Reported concerns;
- Training and awareness;
- Due-diligence activities; and
- Corrective and preventive actions.
Where risks or deficiencies are identified, IAMIT will seek to implement appropriate corrective measures.
16. Responsibilities
Management
Management is responsible for supporting an ethical culture, providing appropriate oversight and ensuring that significant concerns are addressed.
Employees
Employees are expected to:
- Comply with this Policy;
- Act honestly and ethically;
- Respect human rights;
- Avoid bribery and corrupt practices;
- Report suspected violations; and
- Cooperate with legitimate investigations.
Suppliers and Third Parties
Suppliers and third parties working with IAMIT are expected to maintain appropriate standards of ethical conduct, human-rights protection and legal compliance.
17. Policy Violations
Violations of this Policy may result in appropriate action, which may include:
- Corrective action;
- Disciplinary action;
- Termination of employment or engagement;
- Suspension or termination of supplier/business relationships; and
- Referral to relevant authorities where required by law.
18. Our Commitment
IAMIT is committed to operating as a responsible technology and cybersecurity organization that respects people, promotes ethical business practices and maintains responsible relationships with employees, customers, suppliers and business partners.
We will continue to strengthen our processes for identifying, preventing and addressing risks relating to bribery, corruption, human trafficking, modern slavery, forced labour, child labour and other human-rights concerns.
IAMIT has zero tolerance for human trafficking, forced labour, child labour, bribery and corruption.
