Anti-Bribery and Anti-Corruption Policy

1. Scope

This policy applies to all directors, officers, and employees of Onesta, and to agents, intermediaries, distributors, consultants, contractors, and other third parties acting on its behalf, regardless of location.

2. Prohibited conduct

No person covered by this policy shall, directly or indirectly:

• Offer, promise, give, request, agree to receive, or accept a financial or other advantage with the intent to induce or reward the improper performance of a function or activity.
• Make or receive payments to or from public officials or private parties that are not properly documented, lawful, and necessary.
• Use Onesta funds, assets, or resources for unlawful purposes, including political contributions made in the name of Onesta without prior written approval.
• Provide or accept anything of value that could improperly influence a business decision or create an appearance of impropriety.

3. Facilitation payments

Facilitation payments — small, unofficial payments to secure or expedite routine government action — are prohibited regardless of local custom. Where personal safety is at risk, payment may be made, but it shall be reported to the Legal function as soon as practicable.

4. Gifts and hospitality

Modest gifts and hospitality may be exchanged in the ordinary course of business if they are infrequent, of reasonable value, not in cash or cash equivalent, openly given and received, not intended to influence a business decision, and lawful and customary. Gifts and hospitality involving public officials require pre-approval from the Legal function. Records of significant gifts and hospitality given or received shall be maintained.

5. Donations and sponsorships

Charitable donations and sponsorships by Onesta require prior written approval and due diligence on the recipient. They shall not be used to disguise an improper benefit. No political donations may be made in the name of Onesta without prior written approval from the board.

6. Third parties

Third parties acting for or on behalf of Onesta shall be selected through due diligence appropriate to the corruption risk presented. Contracts shall include anti-bribery provisions, audit rights, and termination rights for breach.

7. Books, records, and controls

All transactions shall be accurately and fairly reflected in Onesta's books and records in reasonable detail. False or misleading entries are prohibited. Internal controls relating to financial reporting shall be maintained.

8. Training

Personnel in roles exposed to bribery risk shall receive training on this policy. Training is refreshed at planned intervals and following material changes.

9. Reporting and investigation

Suspected violations of this policy shall be reported to ethics@onestabd.com or through the channels set out in the Whistleblower Policy. Reports are reviewed and investigated under the direction of the Legal function. Onesta does not tolerate retaliation against any person who reports a concern in good faith.

10. Consequences

Violation of this policy by an employee may result in disciplinary action, up to and including termination of employment. Violation by a third party may result in termination of the relationship and may be referred to the authorities. Individuals and entities may also face civil and criminal liability under applicable law.

11. Responsibility

The board endorses this policy. The Managing Director is responsible for ensuring its implementation. The Legal function maintains the policy and supports its application.