Ethics and Anti-Bribery Policy

Purpose

This policy sets out Deliverance AI Limited's commitment to conducting business ethically, honestly, and with integrity, and our zero-tolerance approach to bribery and corruption. It complements our Code of Conduct and explains the responsibilities of everyone who works for or with us.

Scope

This policy applies to all individuals working for or on behalf of Deliverance AI at all levels, including directors, officers, employees, contractors, consultants, interns, agency staff, agents, and any other third party acting in our name ("staff"). Third parties acting for us are expected to act consistently with its principles.

Our ethical commitments

We expect everyone at Deliverance AI to act with honesty and integrity, treat colleagues, customers, and partners fairly and with respect, avoid conflicts of interest, protect confidential information, and comply with all applicable laws. These expectations are set out more fully in our Code of Conduct.

Anti-bribery policy statement

Deliverance AI prohibits bribery and corruption in all forms. Neither staff nor any third party acting on our behalf may offer, promise, give, request, agree to receive, or accept a bribe, directly or indirectly, in the public or private sector, and regardless of the country in which the activity takes place.

Definitions

Bribery is offering, promising, giving, accepting, or soliciting an advantage (financial or otherwise) as an inducement or reward for action that is illegal, unethical, or a breach of trust.

Corruption is the abuse of entrusted power or position for private gain. A facilitation payment is a small unofficial payment to secure or speed up a routine action and is prohibited. A kickback is a payment in return for a business favour or advantage.

The law

Deliverance AI is bound by the UK Bribery Act 2010, which creates offences of bribing another person, being bribed, bribing a foreign public official, and the corporate offence of failing to prevent bribery by associated persons. Where we operate internationally, equivalent laws such as the US Foreign Corrupt Practices Act may also apply. Penalties include unlimited fines and, for individuals, imprisonment of up to 10 years.

Gifts and hospitality

Reasonable and proportionate hospitality given or received in good faith is acceptable. Gifts and hospitality must not be intended to influence a decision, obtain or retain business, or reward such, must comply with local law, must not be cash or cash equivalents, and must be appropriate in type and value.

Email trust@deliverance.ai for our current gifts and hospitality threshold and approval process.

Facilitation payments, kickbacks, and donations

We do not make or accept facilitation payments or kickbacks. We do not make political donations. Charitable donations are permitted only where legal, ethical, not intended to gain a business advantage, approved in advance, and recorded.

Your responsibilities

You must read, understand, and comply with this policy. Preventing, detecting, and reporting bribery and corruption is everyone's responsibility.

• Never engage in any form of bribery, directly or through a third party.
• Avoid any activity that might lead to, or suggest, a breach of this policy.
• Declare and record gifts and hospitality, and keep records of payments to third parties.
• Notify the policy owner promptly if offered a bribe, asked to make one, or if you suspect a breach.

Raising a concern

If you are offered a bribe, asked to make one, or suspect any breach of this policy, report it as soon as possible by emailing trust@deliverance.ai. Concerns may be raised in confidence, and we will not tolerate detrimental treatment of anyone who refuses to take part in bribery or who reports a concern in good faith.

Training, monitoring, and breaches

Awareness of this policy and of the Bribery Act is provided through induction and periodic training. The policy owner monitors effectiveness and reviews this policy at least annually. Any breach may result in disciplinary action up to dismissal for staff, and termination of the relationship for third parties.