Business Principles and Anti-Bribery Pol

ECONiX Business Principles and Anti-Bribery Policy

Effective Date: 01.01.2026

Approved by: ECONiX Management

1. Purpose and Commitment

ECONiX is committed to conducting its business with the highest standards of integrity, transparency, and ethical conduct. We maintain a strict zero-tolerance approach toward bribery, corruption, fraud, and any form of unethical business practice.

This Business Principles and Anti-Bribery Policy (“Policy”) establishes the standards and requirements applicable to all ECONiX directors, officers, employees, contractors, consultants, and third parties acting on behalf of ECONiX.

This Policy is designed to comply with and reflect the principles of applicable international and European anti-corruption laws and regulations, including but not limited to:

The UK Bribery Act 2010
The OECD Convention on Combating Bribery of Foreign Public Officials
Directive (EU) 2017/1371 on the protection of the Union's financial interests
Relevant EU anti-corruption frameworks and national anti-bribery laws
Applicable local anti-corruption and criminal laws in jurisdictions where ECONiX operates

2. Scope

This Policy applies globally to:

All ECONiX employees, officers, and directors
Temporary staff, consultants, and contractors
Agents, intermediaries, distributors, and representatives
Suppliers, vendors, and business partners acting on behalf of ECONiX

All covered persons are required to comply with this Policy regardless of local business customs or practices.

3. Definition of Bribery and Corruption

Bribery is defined as the offering, promising, giving, requesting, or accepting of any financial or other advantage intended to improperly influence a business decision or secure an improper advantage.

Bribes may include, but are not limited to:

Cash payments
Gifts or hospitality exceeding reasonable business practices
Commissions or kickbacks
Favors, services, or personal benefits
Employment opportunities offered to influence decisions
Improper political or charitable contributions

Corruption includes any misuse of entrusted power for private gain.

4. Prohibition of Bribery

ECONiX strictly prohibits:

Offering or giving bribes to public officials or private individuals
Requesting or accepting bribes
Indirect bribery through third parties
Facilitation payments, regardless of amount
Any attempt to improperly influence business decisions

This prohibition applies regardless of whether the payment or advantage is given directly or indirectly.

No employee or representative may engage in bribery under any circumstances, including where such practices may be considered customa0ry in certain jurisdictions.

5. Public Officials

Special care must be taken when interacting with public officials, including:

Government officials
Regulatory authorities
Public healthcare institutions
State-owned enterprises
International organization representatives

Any interaction with public officials must be lawful, transparent, and properly documented.

No improper advantage may be offered or provided to influence official actions.

6. Gifts, Hospitality, and Business Courtesies

ECONiX permits reasonable and proportionate business hospitality that:

Is given in good faith
Is reasonable and customary
Does not influence or appear to influence business decisions
Complies with applicable laws and regulations
Is properly documented

The following are strictly prohibited:

Cash or cash equivalents
Excessive or extravagant gifts
Gifts intended to influence decisions
Gifts provided during active procurement or negotiation processes

7. Third-Party Relationships

ECONiX may be held liable for bribery committed by third parties acting on its behalf.

Therefore, ECONiX:

Conducts appropriate due diligence on business partners
Requires third parties to comply with anti-bribery standards
Avoids engaging third parties with known corruption risks
Monitors relationships for compliance risks

Contracts with third parties may include anti-corruption clauses.

8. Facilitation Payments

Facilitation payments, defined as unofficial payments made to secure or expedite routine governmental actions, are strictly prohibited.

ECONiX does not permit such payments under any circumstances, unless there is an immediate threat to health or safety.

9. Accurate Books and Records

ECONiX maintains accurate, transparent, and complete financial records.

It is strictly prohibited to:

Falsify accounting records
Create misleading financial entries
Conceal improper payments
Maintain off-book accounts

All transactions must be properly documented and reflect their true nature.

10. Reporting Violations

All employees and business partners are encouraged and expected to report suspected violations of this Policy.

Reports may include concerns related to:

Bribery or corruption
Improper payments
Ethical misconduct
Suspicious business practices

Reports may be made confidentially and without fear of retaliation.

ECONiX strictly prohibits retaliation against individuals who report concerns in good faith.

11. Compliance and Enforcement

Violations of this Policy may result in:

Disciplinary action, including termination of employment
Termination of contracts with third parties
Legal action
Reporting to relevant regulatory authorities

Compliance with this Policy is mandatory.

Failure to comply may result in severe legal and financial consequences.

12. Training and Awareness

ECONiX promotes awareness and compliance by:

Providing training where appropriate
Communicating ethical standards clearly
Maintaining internal compliance procedures
Promoting a culture of integrity and accountability

13. Responsibility

All ECONiX personnel share responsibility for maintaining ethical business conduct.

Management is responsible for:

Ensuring effective implementation of this Policy
Promoting compliance culture
Monitoring adherence to ethical standards

14. Policy Review

This Policy may be reviewed and updated periodically to ensure compliance with applicable laws and international best practices.

The most current version will be available on the ECONiX website.

Declaration

ECONiX is committed to ethical, transparent, and lawful business conduct. We do not tolerate bribery or corruption in any form and expect the same commitment from all individuals and organizations working with us.

ECONiX
Ethics, Integrity, and Compliance Commitment.