Spydra Anti-Bribery &
Anti-Corruption Policy

1. Purpose and Scope

This Anti-Bribery and Anti-Corruption Policy outlines Spydra's commitment to conducting business with integrity, ensuring compliance with all applicable laws, and maintaining the highest ethical standards. This policy applies to all employees, directors, officers, contractors, consultants, and any other third parties acting on behalf of Spydra.

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2. Definitions

• Bribery: Offering, giving, receiving, or soliciting any item of value to influence the actions of an official or other person in charge of a public or legal duty.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Small payments made to expedite or secure the performance of a routine governmental action.

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3. Policy Statement

Spydra strictly prohibits any form of bribery and corruption, including facilitation payments. This prohibition extends to all business dealings and transactions in all countries in which Spydra operates.

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4. Compliance with Laws

All employees and associated persons must comply with anti-bribery and anti-corruption laws, including but not limited to:

• The U.S. Foreign Corrupt Practices Act (FCPA)
• The UK Bribery Act
• Local laws in jurisdictions where Spydra operates

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5. Gifts and Hospitality

• Acceptable Gifts and Hospitality: Modest gifts and hospitality that are customary and appropriate in the business context and do not influence or appear to influence business decisions.
• Prohibited Gifts and Hospitality: Gifts or hospitality intended to improperly influence a business decision or secure an unfair advantage.

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6. Facilitation Payments

Spydra prohibits facilitation payments of any kind. Employees should refuse to make such payments and report any requests for facilitation payments to their manager or the Compliance Officer immediately.

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7. Third-Party Relationships

All third parties acting on behalf of Spydra, including agents, consultants, and contractors, must comply with this policy. Spydra will conduct due diligence and require contractual commitments from third parties to ensure compliance with anti-bribery and anti-corruption laws.

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8. Responsibilities

• Employees: Must understand and comply with this policy, attend training, and report any suspected violations.
• Managers: Must ensure their teams understand and comply with this policy and support compliance efforts.
• Compliance Officer: Responsible for overseeing the implementation of this policy, providing training, conducting audits, and investigating reports of non-compliance.

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9. Training and Communication

Spydra provides regular training on anti-bribery and anti-corruption laws and this policy to all employees and relevant third parties. The policy is communicated to all stakeholders and made available on Spydra’s internal and external platforms.

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10. Reporting and Whistleblowing

Employees and third parties are encouraged to report any concerns or suspicions regarding bribery or corruption. Reports can be made confidentially and anonymously through the following channels:

• Internal reporting system
• Directly to the Compliance Officer

Spydra investigates all reports thoroughly and takes appropriate action, including disciplinary measures or termination of contracts, where necessary. Retaliation against individuals who report in good faith is strictly prohibited.

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11. Monitoring and Review

The Compliance Officer monitors the effectiveness of this policy and conducts regular audits. The policy is reviewed annually and updated as necessary to reflect changes in laws or business operations.

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12. Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, including termination of employment or business relationships, and may lead to legal consequences for individuals and the company.

If you have any questions, please contact our team at [email protected].