Introduction

At CG Trade Company LLC, we are committed to conducting business with the highest ethical standards. We have a zero-tolerance policy towards bribery, corruption, and unethical business practices in any form. Our commitment to integrity ensures that we comply with local and international anti-bribery laws, including:

• U.S. Foreign Corrupt Practices Act (FCPA)
• UK Bribery Act
• United Nations Convention Against Corruption (UNCAC)

This policy applies to all employees, partners, suppliers, and third parties associated with CG Trade Company LLC.

Our headquarters is located at 2261 42nd St, Apt B2, Astoria, NY. If you have any questions or concerns regarding compliance, please contact us at info@cgtradecompany.com or call +1 917 512 80 82.

1. What Constitutes Bribery & Corruption?

Bribery is the offering, promising, giving, or receiving of anything of value to improperly influence a decision or gain an unfair advantage. Examples include:

• Cash payments, gifts, or favors intended to secure a contract.
• Kickbacks or commissions paid to influence a business decision.
• Improper facilitation payments to speed up government approvals or permits.

Corruption includes abuse of power, fraud, or unethical behavior that compromises fair business practices.

2. Our Zero-Tolerance Policy

CG Trade Company LLC strictly prohibits:

• Bribing or accepting bribes from government officials, suppliers, or business partners.
• Offering kickbacks or gifts in exchange for business favors.
• Using third parties (agents, consultants, or contractors) to make improper payments on our behalf.
• Making facilitation payments to fast-track government procedures, customs clearance, or business licenses.

Any employee, supplier, or partner found engaging in bribery or corruption will face disciplinary action, including termination of contracts and potential legal prosecution.

3. Gifts & Hospitality Policy

CG Trade Company LLC understands that exchanging small, reasonable gifts or hospitality may be part of normal business interactions. However, such exchanges must:

✅ Be modest, infrequent, and culturally appropriate
✅ Comply with local laws and company policies
✅ Never be offered to influence a business decision

Prohibited Gift Practices:

❌ Large cash gifts or expensive items
❌ Gifts or entertainment that create a conflict of interest
❌ Giving gifts to government officials without prior approval

All employees and business partners must report any gifts received above a reasonable threshold to the compliance department.

4. Third-Party Due Diligence

We carefully assess all third parties (suppliers, agents, consultants) before engaging in business with them. Our third-party compliance checks include:

• Reviewing their reputation for integrity and ethical conduct.
• Verifying their compliance with anti-bribery laws.
• Requiring contractual commitments to uphold our anti-bribery standards.

If a third party is found to be engaged in corrupt activities, CG Trade Company LLC will immediately terminate the relationship and report any illegal actions to the authorities.

5. Political Contributions & Charitable Donations

• CG Trade Company LLC does not make political donations to candidates, parties, or campaigns.
• Charitable donations are only made to legitimate, non-profit organizations and must be approved by management.
• We strictly prohibit donations that could be seen as an attempt to influence business decisions or gain political favors.

6. Employee Responsibilities & Reporting Violations

All employees and business partners are responsible for:

✅ Refusing to participate in bribery or corruption
✅ Reporting any suspicious activities to management
✅ Complying with all anti-bribery laws and policies

Employees and partners are encouraged to report violations confidentially and without fear of retaliation through:

• Email: info@cgtradecompany.com
• Phone: +1 917 512 80 82
• Mailing Address: 2261 42nd St, Apt B2, Astoria, NY

7. Disciplinary Actions for Violations

Violations of this policy may result in:

• Immediate termination of employment or contracts.
• Legal action, including fines or imprisonment under anti-corruption laws.
• Blacklisting from future business dealings with CG Trade Company LLC.

8. Training & Compliance Monitoring

CG Trade Company LLC provides regular anti-bribery training to employees, partners, and suppliers to:

• Raise awareness of bribery risks.
• Ensure compliance with international laws.
• Encourage ethical decision-making in trade practices.

Our compliance team monitors transactions, conducts audits, and enforces this policy across all business operations.

9. Updates to This Policy

We may update this Anti-Bribery & Corruption Policy periodically to reflect changes in laws and best practices. Any updates will be communicated via email, website announcements, or employee training programs.

10. Contact Us

For questions about our anti-bribery policies or to report concerns, please contact:

• Email: info@cgtradecompany.com
• Phone: +1 917 512 80 82
• Mailing Address: 2261 42nd St, Apt B2, Astoria, NY

CG Trade Company LLC is committed to conducting business with integrity, transparency, and accountability. We appreciate your cooperation in upholding ethical trade practices.