ZOIKO WEB SERVICES

Anti-Bribery Policy

REGULATORY & ETHICAL

Anti-Bribery Policy

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Anti-Bribery Policy

Anti-Bribery Policy

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1 · Purpose & scope

2 · What is bribery

3 · Prohibited conduct

4 · Gifts & hospitality

5 · Facilitation payments

6 · Donations & sponsorship

7 · Third parties

8 · Records

9 · Reporting

10 · Consequences

11 · Contact

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Zoiko Tech Inc. is committed to conducting business honestly and ethically. We take a zero- tolerance approach to bribery and corruption and comply with applicable laws, including the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

Purpose and scope

This policy sets out our responsibilities, and those of people working for or on behalf of us, in observing and upholding our position on bribery and corruption. It applies to all employees, officers, directors, contractors, agents, and other third parties acting for or on our behalf.

What is bribery

A bribe is an inducement or reward offered, promised, given, requested, or accepted to gain a commercial, contractual, regulatory, or personal advantage improperly. It can take many forms, including cash, gifts, hospitality, services, or favors, and may be direct or through a third party.

Prohibited conduct

Gifts and hospitality

This policy does not prohibit reasonable and proportionate gifts and hospitality that are given openly, not intended to improperly influence, comply with local law, and are appropriately recorded. Gifts of cash or cash equivalents are not permitted. When in doubt, seek approval before offering or accepting.

Facilitation payments

We do not make and will not accept facilitation payments or kickbacks of any kind, regardless of local custom. If you are asked to make such a payment, you must refuse and report it.

Donations and sponsorship

Charitable donations and sponsorships must be lawful, transparent, and approved in advance. We do not make political contributions to influence business decisions.

Third parties and due diligence

Third parties acting on our behalf can expose us to risk. We conduct risk-based due diligence on intermediaries, include anti-bribery commitments in contracts, and monitor ongoing relationships.

Record-keeping

We keep accurate books and records, and gifts, hospitality, and expenses are recorded transparently. False or misleading records are prohibited.

Reporting and whistleblowing

You must report any suspected bribery or breach of this policy as soon as possible. Reports can be made confidentially and, where permitted, anonymously through our whistleblowing channel.

Speak up: report concerns confidentially at [email protected]. We prohibit retaliation against anyone who reports in good faith.

Consequences of breach

Breaching this policy may result in disciplinary action up to and including termination, and termination of contracts with third parties. Bribery is a criminal offense that can lead to significant penalties for individuals and the company, and matters may be referred to authorities.

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Zoiko Tech Inc.