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ANTI-BRIBERY &
ANTI-CORRUPTION

Effective date: August 18, 2025

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Purpose & Commitment

Algorized conducts business ethically and in full compliance with applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act (UKBA), and relevant local laws. We have zero tolerance for bribery, kickbacks, improper payments, or corrupt practices in either the public or private sector.

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Scope

This Policy applies worldwide to all Algorized employees, officers, directors, interns, and contractors, as well as third parties acting for Algorized (e.g., agents, resellers, suppliers, and consultants). Compliance is mandatory regardless of role, seniority, or local custom.

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Prohibited Conduct

Never—directly or indirectly—offer, promise, authorize, give, request, or accept anything of value to:

  • Improperly influence a decision or official act,

  • Obtain or retain business,

  • Secure an improper advantage, or

  • Induce misuse of a position. 

“Anything of value” includes cash or equivalents (e.g., gift cards), excessive gifts or entertainment, travel or accommodations, jobs or internships, political or charitable contributions, or personal favors.

Facilitation payments (small payments to expedite routine actions) are strictly prohibited, even if common locally.

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Gifts, Hospitality, Travel & Entertainment (GHTE)

GHTE may only be offered or accepted if it is reasonable, infrequent, modest, has a legitimate business purpose, and never intended (or perceived) to improperly influence.

Not allowed: luxury travel or accommodations, lavish or recurring entertainment, or any GHTE during tenders/contract negotiations.

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Government Officials

“Government official” includes any person acting in an official capacity for a government, state-owned/controlled entity, or public international organization (and candidates or political parties).

All gifts, hospitality, travel, or anything of value involving government officials require prior written approval from the CEO.

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Books, Records & Controls

All transactions must be accurately recorded and supported by proper documentation. Off-the-books accounts, false entries, mislabeling, or mischaracterizing payments are forbidden. Algorized maintains internal accounting controls designed to prevent and detect improper payments.

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Third-Party Due Diligence

Third parties can create significant risk. Risk-based due diligence is required before engagement and periodically thereafter, including beneficial-ownership checks and review of red flags (e.g., opaque operations, unusual fees). All third-party contracts must include anti-bribery clauses and audit/termination rights.

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Political & Charitable Contributions

Company political or charitable contributions must never be used to gain improper influence, must be lawful and transparent, and require prior written CEO approval. Personal political or charitable activity must not imply Algorized endorsement or be used to secure business.

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Training & Responsibilities

Relevant personnel receive onboarding and periodic training, with additional training for higher-risk roles or regions. Managers must promote a culture of integrity and ensure team compliance.

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Reporting & Non-Retaliation

You must promptly report suspected violations to management or the CEO (or via any designated reporting channel). Algorized prohibits retaliation against anyone who reports concerns or participates in an investigation in good faith. Reports will be handled confidentially to the extent possible.

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Enforcement & Consequences

Breaches may result in disciplinary action (up to termination), contract termination for third parties, and potential civil/criminal liability for individuals and the company. Full cooperation in audits and investigations is required.

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Governance

This Policy is reviewed at least annually and updated as laws or risks evolve.

Algorized is committed to the highest ethical standards in every market where we operate. This Anti-Bribery & Anti-Corruption Policy reflects our global commitment to integrity, transparency, and compliance with applicable laws. It is intended to share our principles with customers, partners, and the public, and may be supplemented by additional internal procedures for our teams.

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