Anti-Bribery Policy

Last updated 28 October 2024

Purpose
This policy outlines Ayora Technologies Limited's stance against bribery and corruption, and the steps we take to prevent, detect, and address any such activities.

Scope
This policy applies to all employees, officers, directors, suppliers, and other third parties acting on behalf of Ayora Technologies Limited globally.

Policy
Ayora Technologies Limited is committed to operating with the highest standards of integrity and ethics. We have a zero-tolerance approach to bribery and corruption in any form.Employees, officers, directors, and suppliers must not:
- Offer, promise, give, request, agree to receive, or accept a bribe
- Make facilitation payments (small payments to government officials to expedite routine actions)
- Engage in any other corrupt practices

Modest gifts and hospitality form a normal part of developing business relationships. However, excessive gifts and hospitality can be perceived as bribes. To this end, gifts and hospitality must be transparently recorded, proportionate, and reasonable. There must never be a suggestion that a gift or hospitality was offered or received on the assumption of certain favors being granted. Third parties acting on our behalf must also comply with this policy. We conduct due diligence on all third parties and include antibribery clauses in contracts.

Ayora Technologies Limited does not regard its activities as posing a high risk of bribery requiring further steps. Measures taken must be practical and commensurate with levels of risk.

Reporting and Investigation
Employees, officers, directors, and suppliers must report any suspected or actual incidents of bribery or corruption to the CEO and CTO immediately. Ayora Technologies Limited will investigate all reports and take appropriate disciplinary, contractual, and legal action.

Retaliation against anyone who reports a concern in good faith is strictly prohibited.

Training and Monitoring
Ayora Technologies Limited provides regular antibribery training for all relevant employees, officers, and directors. We also have controls in place to monitor compliance with this policy, such as audits, expense reviews, and supplier assessments.

Consequences
Violations of this policy may result in disciplinary action for employees, termination of contracts for suppliers, and removal from position for officers and directors. Violations may also lead to criminal penalties for the individual and Ayora Technologies Limited.

Approval
This Policy has been approved by the organisation's Senior Management Team, who will review and update it annually.