Anti-Bribery & Anti-Corruption Policy

[Company] strictly prohibits bribery, kickbacks, and any improper payments — whether offered, given, requested, or received. This applies to dealings with government officials, customers, suppliers, agents, and any third party.

Modest gifts and entertainment are acceptable when: (a) infrequent, (b) reasonable in value (typically <$100), (c) appropriate to the business context, (d) not given to influence a specific decision, and (e) properly recorded. Gifts to government officials require pre-approval from Legal.

Small payments to expedite routine governmental actions (“facilitation payments”) are prohibited under our policy and the UK Bribery Act, even where permitted under the FCPA. If you face a demand for such a payment, refuse and contact Legal immediately.

[Company] may be liable for bribes paid by agents, distributors, or other third parties acting on its behalf. All third parties undergo due diligence proportionate to risk. Third parties are required to acknowledge this policy and provide audit rights.

Charitable contributions on behalf of the company require pre-approval from Legal. Political contributions to government officials or candidates are not made by the company in any jurisdiction. Personal political activity by employees is not restricted.

All payments must be recorded accurately in company books and records. False entries to disguise payments are themselves an FCPA violation. No off-books accounts are permitted.

Suspected violations must be reported via the ethics hotline, Legal, or the Audit Committee. All reports are investigated. Anti-retaliation protections apply.