At Datazoom Inc., we are committed to conducting our business with integrity, honesty, and transparency. Bribery and corruption undermine these values and have no place in our organization. As such, we have established the following anti-bribery code of conduct to guide the behavior of all employees, contractors, agents, and representatives of our company:

1. Zero Tolerance Policy: We maintain a zero-tolerance policy towards bribery and corruption in all its forms, whether direct or indirect.
2. Compliance with Laws and Regulations: All employees must comply with the anti-bribery laws and regulations applicable in the jurisdictions where we operate, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
3. Prohibited Activities: Employees are prohibited from offering, giving, receiving, or soliciting bribes or other improper advantages, whether in cash or in any other form, to or from any person or organization, including government officials, customers, suppliers, competitors, or any other third parties.
4. Gifts, Entertainment, and Hospitality: Gifts, entertainment, and hospitality may be offered or accepted only if they are modest, appropriate, and consistent with customary business practices, and do not create a conflict of interest or the appearance of impropriety. Employees must obtain approval from their supervisor or the compliance department for gifts, entertainment, or hospitality exceeding predefined thresholds.
5. Transparency and Record-Keeping: All transactions and payments must be accurately and transparently recorded in the company’s books and records. False, incomplete, or misleading entries are strictly prohibited.
6. Due Diligence on Third Parties: Before engaging with third parties, including agents, consultants, suppliers, and business partners, employees must conduct due diligence to assess their integrity, reputation, and compliance with anti-bribery laws and regulations.
7. Reporting and Whistleblowing: Employees are encouraged to report any suspected violations of this code of conduct, including instances of bribery or corruption, to their supervisor, the compliance department, or through the company’s whistleblower hotline. Reports will be promptly and thoroughly investigated, and appropriate disciplinary action will be taken against violators.
8. Training and Awareness: All employees will receive regular training on anti-bribery laws, regulations, and company policies to ensure awareness and understanding of their obligations under this code of conduct.
9. Continuous Improvement: We are committed to continuously reviewing and improving our anti-bribery policies, procedures, and controls to prevent and detect instances of bribery and corruption effectively.
10. Consequences of Non-Compliance: Violations of this code of conduct may result in disciplinary action, up to and including termination of employment, as well as civil or criminal penalties for individuals involved in bribery or corruption.

By adhering to this anti-bribery code of conduct, we demonstrate our commitment to ethical business practices and uphold the reputation and integrity of Datazoom Inc.