Anti-Bribery & Corruption Policy

Voltade Pte. Ltd. ("Voltade", UEN 202307668E) conducts business honestly, ethically, and in compliance with all applicable anti-bribery and corruption laws, including the Prevention of Corruption Act 1960 of Singapore and, where applicable, laws with extraterritorial effect such as the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act.

This policy applies to all Voltade directors, employees, and contractors, and to any third party acting on Voltade's behalf. It forms part of our commitment to the codes of conduct of the enterprise customers and business partners we serve.

Voltade prohibits offering, promising, giving, requesting, or accepting any bribe, kickback, facilitation payment, or other improper advantage, directly or through an intermediary, in order to obtain or retain business or to influence any decision. This applies equally in the public and private sectors.

• No payments or benefits of any kind to improperly influence a business or official decision
• No facilitation or "grease" payments, even where locally customary
• Only lawful, appropriate, documented, and transparent remuneration and business expenses are permitted

Modest and reasonable business courtesies are only acceptable where they are lawful, transparent, infrequent, and could not reasonably be perceived as influencing a business decision. The following rules apply:

• Cash or cash equivalents (vouchers, gift cards) are never given or accepted
• Gifts, entertainment, or hospitality beyond a nominal value must be declared to and approved by management
• Nothing of value may be offered to or accepted from a counterparty during an active tender, negotiation, or procurement decision
• We respect the stricter gift rules of our customers and partners: where a partner's code of conduct prohibits business courtesies to its employees, Voltade personnel offer none

Voltade does not ordinarily interact with government officials on behalf of customers. Where any interaction with a public official is required (for example, grant administration or regulatory filings), heightened diligence applies: interactions are documented, handled by management, and never involve any payment or benefit beyond published official fees.

• Voltade makes no political contributions of any kind
• Charitable donations and sponsorships require management approval, are made only to legitimate organisations, and are never made at the request of, or for the benefit of, any government official or to influence a decision
• Voltade does not engage third parties, agents, or intermediaries to interact with government officials on its behalf

Voltade is committed to preventing its services and finances from being used for money laundering or the financing of terrorism, and complies with applicable AML/CFT laws and regulations. Our internal controls include:

• Know-your-counterparty checks on customers and suppliers before entering a business relationship
• All payments made and received through traceable bank transfers to and from contracted parties only; no cash transactions
• No payments to or from third parties that are not a party to the underlying contract, to or from accounts in countries unrelated to the transaction, or split across multiple accounts
• Unusual payment requests are escalated to management and refused where legitimacy cannot be established

Voltade complies with all applicable economic sanctions and trade control laws, including those of the United Nations, Singapore, the European Union, the United Kingdom, and the United States. Voltade is incorporated in Singapore, operates from Singapore, and has no operations, dealings, or affiliates in any country subject to comprehensive sanctions, nor any dealings involving Russia or Belarus.

• Customers and suppliers are screened against applicable sanctions lists before onboarding
• Voltade will not conduct business with sanctioned persons or entities, or within sanctioned countries
• Our services are business software and are not strategic goods or dual-use items under the Strategic Goods (Control) Act 2002 of Singapore

Voltade performs due diligence on the third-party service providers it relies on (see our subprocessor list), selects providers with recognised security and compliance certifications, and imposes contractual obligations, including data protection and lawful conduct, consistent with this policy. Voltade does not subcontract customer engagements to third parties without the customer's knowledge and agreement.

Suspected violations of this policy can be reported, anonymously if preferred, through the channels in our Whistleblowing Policy. Retaliation against anyone who reports a concern in good faith is strictly prohibited. Violations of this policy result in disciplinary action up to and including termination of employment or contract, and referral to the relevant authorities where required by law.

Neither Voltade nor any of its directors, officers, or employees has ever been convicted of, prosecuted for, or investigated in relation to bribery, corruption, money laundering, or sanctions violations.