ABC Anti-Corruption Policy

DEUNA is committed to maintaining the highest ethical and legal standards in all its
operations. This anti-corruption policy establishes guidelines and expectations to prevent and combat corruption in all its forms within our organization.

Scope: This policy applies to all employees, directors, officers, consultants,
contractors, agents, suppliers, and any other individuals acting on behalf of DEUNA. It also extends to all subsidiaries, affiliates, and entities in which DEUNA holds a majority interest.

Definitions:

Corruption: Any form of bribery, extortion, fraud, influence peddling, money
laundering, or any other illicit activity related to obtaining undue benefits.
Bribery: The offer, promise, delivery, acceptance, or request of any
unauthorized benefit to influence the decision-making of a person in a position of power.
Facilitation Payments: Small payments made to secure or expedite the
performance of a routine action by a public official.

General Principles

Zero Tolerance: DEUNA adopts a zero-tolerance policy toward any form of
corruption.
Legal Compliance: All employees must comply with applicable anti-corruption
laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
Integrity and Transparency: All operations and transactions must be
conducted transparently and documented properly.

Rules and Prohibitions

Prohibition on Bribery and Facilitation Payments: Offering, giving, receiving, or
soliciting bribes or facilitation payments is strictly prohibited.
Gifts and Hospitality: Gifts and hospitality must be reasonable, infrequent, and
in compliance with DEUNA policies. They must not be offered or received with the intent to influence business decisions.
Donations and Sponsorships: All donations and sponsorships must be
approved by senior management and must not be used as a means to conceal corrupt payments.

Responsibilities

Reporting Duty: Employees must report any suspected corruption or violation
of this policy to their immediate supervisor. If this is not possible, they should report it to Human Resources.
Training: DEUNA will provide regular training to all employees on
anti-corruption laws and this policy.
Audits: Audits and due diligence assessments will be conducted before
establishing business relationships with third parties to ensure they are not involved in corrupt practices.

Compliance

Internal Investigations: Any report of potential corruption will be thoroughly
and confidentially investigated.
Sanctions: Violations of this policy may result in severe disciplinary actions,
including termination of employment and possible legal action.

This policy will be periodically reviewed and updated to ensure its effectiveness and
compliance with applicable laws and regulations.

The DEUNA anti-corruption policy will be communicated to all employees and made
available on the DEUNA website and in the Code of Conduct.

DEUNA’s senior management is committed to leading by example, fostering a culture
of integrity and ethics at all levels of the organization.