1. Introduction

Suprdense (“the Company,” “we,” “us,” or “our”) is committed to conducting business ethically and in full compliance with all applicable laws and regulations relating to anti-bribery and corruption. This Anti-Bribery & Corruption Policy (“Policy”) sets out our zero-tolerance stance on bribery and outlines the standards and procedures that must be followed to prevent any form of corrupt activity.

2. Purpose & Scope

1. Purpose:
   1. Affirm Suprdense’s commitment to honest and transparent business dealings.
   2. Provide guidance on identifying and preventing bribery and corruption.
   3. Establish responsibilities for reporting, investigating, and remediating any bribery-related concerns.
2. Scope:
   1. Applies to all Suprdense employees, officers, directors, contractors, consultants, and anyone acting on behalf of Suprdense.
   2. Covers all transactions and interactions with government officials, customers, suppliers, partners, and any other third parties.

3. Definitions

1. Bribery: The offering, giving, promising, or receiving (or the solicitation of) any undue advantage, financial or otherwise, with the intention of influencing the actions of the recipient in an unethical or unlawful manner.
2. Corruption: The misuse of a position of trust or power to gain an improper advantage for oneself or another.
3. Facilitation Payments: Typically small or unofficial payments made to expedite or secure the performance of a routine or necessary action to which the payer already has a legal or other entitlement.

4. Policy Statement

1. Zero Tolerance:
   1. Suprdense has a zero-tolerance policy regarding bribery and corruption. Any engagement in bribery or corrupt practices is strictly prohibited.
2. Compliance with Laws:
   1. Suprdense complies with all applicable local and international laws and regulations aimed at preventing bribery and corruption, such as the UK Bribery Act, the U.S. Foreign Corrupt Practices Act (FCPA), and equivalent anti-corruption laws worldwide.
3. Prohibited Conduct:
   1. Bribing or Attempting to Bribe: No one acting on behalf of Suprdense may offer, promise, give, or authorize the giving of anything of value to gain an improper business advantage.
   2. Receiving Bribes: Suprdense personnel must never solicit or accept any bribe or personal inducement.
   3. Facilitation Payments: Suprdense prohibits facilitation payments of any kind, including those made to government officials or private individuals to expedite routine actions.

5. Gifts & Hospitality

1. Reasonable & Proportionate:
   1. Gifts, hospitality, or entertainment offered or received on behalf of Suprdense must be lawful, modest in value, and not intended to improperly influence any business decision.
   2. Excessive, frequent, or lavish gifts or hospitality can constitute (or be perceived as) bribery or a conflict of interest.
2. Pre-Approval & Transparency:
   1. Any gift or hospitality with a value exceeding the threshold of $100 or equivalent local currency should be reported to or pre-approved by senior management or the Chief Executive Officer.
   2. Records of such gifts or hospitality must be accurately documented in Suprdense’s internal systems.
3. Government Officials:
   1. Special caution must be exercised when offering or providing gifts and hospitality to government officials, as many jurisdictions strictly regulate or forbid these practices.

6. Due Diligence for Third Parties & Partners

1. Risk Assessment:
   1. Prior to engaging any third-party agents, consultants, distributors, or business partners, Suprdense performs risk-based due diligence to identify potential bribery or corruption risks.
   2. High-risk factors such as operating in a jurisdiction with a history of corruption require enhanced scrutiny and management approval.
2. Contractual Safeguards:
   1. Contracts with third parties should include anti-bribery clauses that obligate them to comply with applicable laws and Suprdense’s standards.
   2. Contracts should also include provisions that allow Suprdense to terminate the relationship if bribery or other corrupt behavior is discovered.
3. Ongoing Monitoring:
   1. Suprdense may conduct periodic reviews or audits of high-risk partners to ensure ongoing compliance with anti-bribery regulations.

7. Reporting & Whistleblowing

1. Reporting Obligations:
   1. Any individual who suspects or becomes aware of violations of this Policy (including attempts or offers of bribes) must immediately report the issue to their manager, the Chief Executive Officer, or through the anonymous whistleblowing channel (where available).
2. Whistleblower Protection:
   1. Suprdense prohibits retaliation against anyone who reports, in good faith, a concern about possible misconduct. This protection extends to individuals who refuse to participate in any potentially unlawful or unethical activity.
3. Investigation Process:
   1. The Chief Executive Officer (or designated investigatory team) will promptly and thoroughly investigate all reported concerns.
   2. Suprdense cooperates fully with law enforcement or regulatory bodies during investigations.

8. Record-Keeping & Accounting

1. Accurate Financial Records:
   1. All financial transactions, invoices, and expense reports must be accurate, complete, and transparently recorded in Suprdense’s books and records.
   2. False or misleading entries such as hiding or disguising payments are strictly prohibited.
2. Retention:
   1. Relevant documentation including, but not limited to, invoices, receipts, and agreements must be kept in accordance with the Suprdense Data & Log Retention Policy and any legal requirements.

9. Training & Awareness

1. Mandatory Training:
   1. All Suprdense employees and relevant contractors must complete anti-bribery training upon joining and at regular intervals thereafter.
   2. Specialized, in-depth training is provided for high-risk roles including, but not limited to, sales, engineering, and finance or those with direct dealings in jurisdictions with elevated corruption risk.
2. Ongoing Awareness:
   1. Regular reminders, updates, and communications are provided to reinforce the importance of compliance with anti-bribery and corruption standards.

10. Enforcement & Sanctions

1. Disciplinary Measures:
   1. Breaches of this Policy may result in disciplinary action up to and including termination of employment or contract, consistent with relevant labor laws and contractual obligations.
   2. In cases where laws may have been violated, Suprdense will consider referring the matter to the appropriate regulatory and law enforcement authorities.
2. Zero Tolerance:
   1. Suprdense applies the same standard of enforcement regardless of an individual’s position, seniority, or length of service. No exception is made for “facilitation payments” or “common practices.”

11. Roles & Responsibilities

1. Executive Management:
   1. Leads by example, setting the tone at the top and ensuring the necessary resources and support for effective implementation of this Policy.
2. Chief Executive Officer:
   1. Maintains and updates this Policy, responds to queries, and oversees investigations of suspected violations.
   2. Works with HR to develop and deliver regular anti-bribery training.
3. All Employees & Contractors:
   1. Abide by this Policy at all times, remain vigilant for signs of bribery or corruption, and immediately report concerns as per Section 7.

12. Contact & Further Information

For questions or more information regarding this Suprdense Modern Slavery Statement, please contact:

Nishant Gupta
Chief Executive Officer
Suprdense
talk@suprdense.com