Purpose

PolymathPlus is committed to conducting business ethically, transparently, and in full compliance with all applicable anti‑corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. This policy sets forth our standards for preventing bribery and corruption in all jurisdictions where we operate.

Scope

This policy applies to all PolymathPlus employees, officers, contractors, agents, and third‑party representatives, worldwide.

Policy Statement

• Zero Tolerance: No employee or representative may offer, promise, give, request, or accept any bribe, kickback, or improper payment to influence business decisions.
• Gifts & Hospitality: Permitted only when modest, infrequent, and never intended to secure an improper advantage. All gifts or hospitality must be recorded and approved by Management.

Roles & Responsibilities

• Board of Directors: Endorses and enforces this policy.
• Compliance Officer: Oversees implementation, provides guidance, and conducts risk assessments.
• Managers: Ensure team members understand and comply, escalate concerns promptly.
• Employees & Contractors: Participate in training, follow procedures, and report any suspected violations.

Training & Communication

All relevant personnel must complete anti‑bribery training upon hire and annually thereafter. This policy will be available in the Employee Handbook and on the company intranet.

Due Diligence & Controls

• Third Parties: Conduct risk‑based due diligence on agents, resellers, and partners before engagement.
• Financial Controls: Maintain accurate books and records; never falsify or conceal transactions.

Reporting & Investigation

Employees must report concerns or suspected violations via the confidential hotline or directly to the Compliance Officer. All reports will be investigated promptly, fairly, and discretely.

Disciplinary Measures

Violations of this policy may result in disciplinary action up to and including termination of employment or contract, and referral to legal authorities if warranted.

Review and Maintenance

This Policy will be reviewed annually and updated as necessary to reflect changes in law or business practice. Any changes to the process will be communicated to all employees and relevant stakeholders.

Contact Information

For questions or further information regarding this policy, please contact:

PolymathPlus LLC
admin@polymathplus.com

Effective Date: May 10, 2025

Review Date: May 10, 2025

Version: 1.0