Transparency & Anti-Corruption Policy

Zwaya Jobs is committed to conducting its business with integrity, transparency, fairness, and accountability.

As a digital platform connecting job seekers, professionals, freelancers, employers, and businesses, we recognise that trust depends on honest communication, responsible commercial practices, and the prevention of bribery, corruption, fraud, and improper influence.

This Transparency & Anti-Corruption Policy (“Policy”) establishes the principles and standards governing ethical conduct in the operation of Zwaya Jobs and its relationships with users, employees, business partners, service providers, and other stakeholders.

Zwaya Jobs maintains a zero-tolerance position toward bribery, corruption, fraudulent inducements, and the misuse of professional or commercial relationships for improper advantage.

Our commitment is to promote genuine opportunities, fair business dealings, transparent platform practices, and responsible decision-making.

This Policy should be read alongside the Zwaya Jobs Terms & Conditions, User Conduct Policy, Privacy Policy, and other applicable platform policies.

This Policy applies to the operations of Zwaya Jobs and, where relevant to their relationship with the Company, to:

• Directors, officers, managers, and employees.
• Contractors, consultants, and authorised representatives.
• Employers, recruiters, and business users.
• Job seekers, freelancers, and professional service providers.
• Suppliers, commercial partners, and service providers.
• Training providers and other parties conducting business through or on behalf of Zwaya Jobs.

Employees, representatives, and persons acting on behalf of Zwaya Jobs must comply with this Policy in the performance of their duties.

Independent users and third parties are required to comply with the provisions applicable to their use of the Platform or their contractual relationship with Zwaya Jobs.

This Policy applies to relevant activities conducted within Iraq and internationally, subject to applicable laws and contractual obligations.

Zwaya Jobs is guided by the following principles:

Honesty:

Providing accurate and reliable information about our services, fees, and business practices.

Fairness:

Treating users and business partners impartially and avoiding improper preferential treatment.

Accountability:

Taking responsibility for decisions, conduct, and obligations within our control.

Integrity:

Rejecting bribery, corruption, fraud, and improper influence.

Transparency:

Communicating material commercial conditions clearly and avoiding misleading representations.

Confidentiality:

Protecting personal, professional, and commercially sensitive information.

Legal Compliance:

Conducting business in accordance with applicable anti-corruption, financial, commercial, and other legal requirements.

These principles guide our commercial relationships, internal decision-making, and the standards expected of parties using the Platform.

Zwaya Jobs prohibits bribery, corruption, kickbacks, and improper payments in connection with its business activities.

No person acting for or on behalf of Zwaya Jobs may directly or indirectly offer, promise, give, request, solicit, accept, or authorise anything of value for the purpose of improperly influencing a decision or obtaining an unfair advantage.

This prohibition applies to dealings with:

• Public officials and government representatives.
• Private companies and commercial organisations.
• Employers, recruiters, and recruitment intermediaries.
• Suppliers, contractors, and service providers.
• Job seekers, freelancers, and other Platform users.
• Any other person or organisation involved in Zwaya Jobs' business activities.

Bribery may involve money, gifts, commissions, employment opportunities, favours, hospitality, benefits, or other items of value.

An improper benefit does not need to be paid or received for conduct to raise a serious compliance concern.

Zwaya Jobs does not permit bribery or corruption through intermediaries, agents, consultants, or other third parties.

Zwaya Jobs supports recruitment practices based on genuine opportunities, professional qualifications, and lawful selection criteria.

Employers and recruiters using the Platform must conduct recruitment activities honestly and must not use the Platform to facilitate bribery, fraudulent hiring arrangements, or unlawful financial demands.

The following practices are prohibited:

• Offering or requesting bribes in exchange for employment opportunities.
• Demanding unlawful payments from applicants to secure interviews, job offers, or employment.
• Selling or falsely promising access to employment positions.
• Misrepresenting the authority to recruit on behalf of an employer.
• Publishing fictitious vacancies to obtain payments or personal information.
• Offering employment in exchange for improper personal or financial benefits.
• Manipulating recruitment processes through undisclosed improper payments or inducements.
• Facilitating exploitation, forced labour, trafficking, or other unlawful employment practices.

Legitimate, lawfully permitted recruitment service fees must be distinguished clearly from unlawful payments or fraudulent charges.

Employers remain responsible for their own hiring decisions and compliance with applicable employment laws.

Zwaya Jobs may investigate credible reports of improper recruitment conduct and take appropriate action under its Terms & Conditions and User Conduct Policy.

Zwaya Jobs is committed to communicating the material conditions of its services clearly.

Where services are offered for a fee, users should be informed of the applicable charges, service scope, billing arrangements, and material purchase conditions before confirming a transaction.

Paid services may include subscriptions, promoted listings, recruitment features, advertising, courses, or other offerings expressly identified as paid services.

Zwaya Jobs will not knowingly misrepresent the nature, price, or availability of its services.

Where subscription services automatically renew, the relevant renewal and cancellation conditions must be disclosed before purchase.

Payments are processed through third-party payment service providers, and applicable payment conditions will be communicated through the relevant service arrangements.

Refund eligibility and cancellation rights are governed by the Refund & Dispute Resolution Policy and applicable law.

No user or business partner is authorised to demand unofficial payments while falsely representing them as mandatory Zwaya Jobs charges.

A conflict of interest may arise when personal, financial, professional, or other interests interfere with, or appear reasonably capable of interfering with, objective decision-making.

Persons acting on behalf of Zwaya Jobs must avoid conflicts that compromise their responsibilities to the Company or its users.

Potential conflicts may include:

• Awarding business opportunities to related parties without appropriate disclosure or review.
• Receiving personal benefits from suppliers or commercial partners in exchange for favourable treatment.
• Using confidential business information for private advantage.
• Participating in decisions involving undisclosed financial or personal interests.
• Accepting improper incentives connected with recruitment, advertising, or commercial arrangements.

Employees, managers, contractors, and authorised representatives must disclose material conflicts through the Company's designated internal reporting process.

Where necessary, appropriate measures may include independent review, reassignment of decision-making responsibility, additional approval, or withdrawal from the relevant transaction.

Independent Platform users must not engage in fraudulent or corrupt conduct involving undisclosed conflicts of interest.

Reasonable gifts, hospitality, or business courtesies may be acceptable where they are lawful, proportionate, transparent, and unrelated to any improper influence.

Gifts or benefits must not be offered or accepted where their purpose or likely effect is to influence a business decision improperly.

Persons acting on behalf of Zwaya Jobs must not:

• Request personal gifts or benefits in exchange for performing their duties.
• Accept cash or cash-equivalent gifts intended to influence decisions.
• Offer benefits to obtain unlawful or improper commercial advantages.
• Conceal gifts, hospitality, or benefits that create material conflicts of interest.
• Provide gifts or hospitality prohibited by applicable law.

Particular caution is required in dealings with public officials and persons exercising regulatory or procurement authority.

The Company may establish internal approval thresholds, registers, or additional procedures for gifts and hospitality according to operational needs.

Zwaya Jobs is committed to conducting its interactions with public authorities lawfully and professionally.

No employee, representative, contractor, or intermediary acting on behalf of Zwaya Jobs may offer or provide an improper benefit to a public official to influence an official act or decision.

This includes attempts to obtain:

• Licences, permits, or registrations improperly.
• Preferential regulatory treatment.
• Unlawful exemptions or approvals.
• Improper access to government contracts or opportunities.
• Confidential government information.
• Unlawful acceleration of official procedures.

Unofficial facilitation payments intended to secure or accelerate routine official actions are prohibited, except where a payment is legally required and properly documented as an official charge.

Where an individual faces an immediate threat to personal safety, protecting life and safety takes priority. Any payment made under genuine duress must be reported promptly and documented accurately.

Legitimate official fees must be paid through authorised channels and supported by appropriate records.

Zwaya Jobs expects suppliers, contractors, commercial partners, and service providers to conduct their activities lawfully and ethically.

Where appropriate to the nature and risk of the relationship, Zwaya Jobs may conduct reasonable checks before entering into or continuing commercial arrangements.

Relevant considerations may include:

• Business identity and legal registration.
• Authority to provide the relevant services.
• Reputation and relevant compliance concerns.
• Ownership or control information where legally required.
• Potential conflicts of interest.
• Unusual payment requests or commercial arrangements.
• Evidence of fraud, bribery, corruption, or unlawful activity.

Persons acting on behalf of Zwaya Jobs must not use third parties to carry out conduct prohibited by this Policy.

Contracts with higher-risk business partners may include appropriate anti-corruption commitments, reporting obligations, and termination rights.

Zwaya Jobs is committed to maintaining accurate business and financial records consistent with applicable accounting, tax, and legal requirements.

Business transactions are recorded to reflect their nature, purpose and value accurately.

The following practices are prohibited:

• Falsifying invoices, receipts, or transaction records.
• Creating fictitious expenses or misleading accounting entries.
• Concealing improper payments.
• Using Company funds for unauthorised personal purposes.
• Misrepresenting the purpose or recipient of payments.
• Maintaining undisclosed funds intended to facilitate improper conduct.
• Knowingly providing false financial information to relevant authorities or business partners.

Payments made by or on behalf of Zwaya Jobs require appropriate authorisation and accurate records.

Unusual payment requests or arrangements are subject to additional scrutiny before approval.

Zwaya Jobs prohibits fraud, identity misrepresentation, deceptive commercial conduct, and the misuse of its Platform for unlawful financial gain.

Prohibited activities include:

• Creating fraudulent employer or professional accounts.
• Publishing misleading job advertisements for financial gain.
• Impersonating Zwaya Jobs representatives.
• Soliciting unofficial fees through false claims of Platform authority.
• Submitting fabricated payment confirmations or invoices.
• Using stolen or unauthorised payment credentials.
• Misrepresenting professional qualifications or business credentials to obtain improper benefits.
• Using the Platform to facilitate unlawful financial transactions.

Zwaya Jobs may restrict accounts or transactions where credible evidence indicates fraudulent activity, subject to applicable law and the Terms & Conditions.

Zwaya Jobs supports fair and lawful competition in its commercial activities.

Persons acting on behalf of the Company must not participate in unlawful arrangements intended to distort competition or improperly restrict market access.

This includes prohibited price-fixing, bid-rigging, unlawful market allocation, and other anti-competitive conduct.

Commercial decisions must be based on legitimate business considerations, including service quality, suitability, price, reliability, and contractual requirements.

Zwaya Jobs must not misuse confidential competitor information or obtain commercial advantages through unlawful methods.

Employers and other business users remain responsible for ensuring that their own commercial conduct complies with applicable competition laws.

Zwaya Jobs recognises that transparency must be balanced with the protection of personal information, confidential business records, and legitimate commercial interests.

Confidential information must not be disclosed, accessed, or used without appropriate authorisation.

This includes:

• Candidate CVs and personal information.
• Employer recruitment records.
• Confidential commercial arrangements.
• Non-public financial information.
• Business strategies and proprietary materials.
• Account credentials and security-related information.

Information must not be used to obtain improper personal, financial, or competitive advantages.

Personal information is handled in accordance with the Zwaya Jobs Privacy Policy and applicable law.

Nothing in this Policy requires disclosure of information protected by legal privilege, confidentiality obligations, privacy law, or other applicable legal restrictions.

Zwaya Jobs encourages the reporting of suspected bribery, corruption, fraudulent recruitment, conflicts of interest, or other serious violations of this Policy.

Reports may be submitted through available official reporting channels or by contacting:

Email

info@zwayajobs.com

Reports should include relevant details, such as the nature of the concern, the parties involved, the approximate date, and any supporting information lawfully available to the reporting person.

Individuals should not obtain evidence through unlawful access or other prohibited activities.

Reports may be made in good faith even where the reporting person does not have conclusive proof of wrongdoing.

Knowingly submitting false allegations for malicious purposes is prohibited.

Zwaya Jobs will assess reports according to their seriousness, available evidence, and applicable legal requirements.

Zwaya Jobs does not tolerate retaliation against individuals who report suspected misconduct in good faith or cooperate with a legitimate investigation.

Prohibited retaliation may include threats, harassment, unjustified adverse treatment, or other improper actions intended to punish a person for raising a concern.

Reports will be handled with appropriate discretion, taking account of confidentiality, fairness, investigation requirements, and applicable law.

Absolute anonymity or confidentiality cannot be guaranteed where disclosure is legally required or reasonably necessary for a fair investigation.

Any person who believes they have experienced retaliation connected with a good-faith report should raise the concern through an appropriate reporting channel.

Protection against retaliation does not prevent legitimate action in response to independently established misconduct.

Zwaya Jobs may review credible reports of suspected bribery, corruption, fraud, or other serious misconduct.

The response will depend on the nature of the allegation, the evidence available, the potential risks, and applicable legal obligations.

Appropriate measures may include:

• Requesting additional information.
• Reviewing relevant records or transactions.
• Restricting access to affected accounts or services.
• Suspending suspicious activities while concerns are assessed.
• Taking disciplinary or contractual action where justified.
• Terminating commercial relationships for serious violations.
• Reporting suspected unlawful conduct to competent authorities where required or appropriate.
• Implementing corrective measures to reduce the risk of recurrence.

We approach investigations fairly and proportionately, taking account of confidentiality and the rights of affected individuals.

Zwaya Jobs does not guarantee that every allegation will result in a formal investigation or a particular outcome.

The management of Zwaya Jobs is responsible for establishing an appropriate ethical and compliance framework proportionate to the Company's operations and risks.

Persons acting on behalf of the Company are expected to understand and comply with the standards relevant to their duties.

Internal responsibilities may include:

• Communicating applicable ethical standards.
• Identifying and addressing material corruption risks.
• Reviewing relevant conflicts of interest.
• Maintaining appropriate financial and approval controls.
• Assessing credible reports of misconduct.
• Taking corrective action where necessary.
• Reviewing this Policy periodically.

The Company may introduce additional internal procedures, training, approvals, or monitoring measures as its operations develop.

The absence of a specific internal procedure does not authorise conduct prohibited by applicable law or this Policy.

Zwaya Jobs operates from Iraq and is committed to complying with applicable Iraqi laws and regulations relating to bribery, corruption, fraud, commercial conduct, and financial integrity.

Where the Company conducts activities or establishes business relationships in other jurisdictions, additional legal requirements may apply.

Depending on the circumstances, these may include applicable foreign anti-bribery and anti-corruption laws.

Zwaya Jobs supports internationally recognised principles of business integrity, including those reflected in the United Nations Convention against Corruption.

This Policy also draws on recognised anti-bribery management principles, including risk assessment, appropriate controls, accountability, and reporting.

References to international standards do not constitute a claim that Zwaya Jobs holds a particular compliance certification or has implemented a formally certified anti-bribery management system.

Zwaya Jobs may review and update this Policy to reflect changes in business operations, identified risks, legal requirements, or relevant compliance practices.

The latest version will be published on the Zwaya Jobs website with its effective or revision date.

Material changes affecting users or business partners will be communicated where required by applicable law or contractual obligations.

Users and relevant business partners are encouraged to review the Policy periodically.

For questions about this Policy, ethical concerns, suspected corruption, or reports of improper conduct, please contact:

Brand

ZWAYA JOBS

Operating Company

ZWAYA AL IRAQ FOR ONLINE SERVICES, ONLINE MARKETING, ADVERTISING AND PUBLICITY LLC

Company Registration Number

M.Sh.A. - 2 -3285

Address

Baghdad, Iraq

Website

www.zwayajobs.com

Email

info@zwayajobs.com

Zwaya Jobs is committed to promoting ethical business practices, responsible recruitment, and transparent professional relationships.