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Anti-Bribery and Anti-Corruption Policy

Last updated: May 10, 2025

1. Policy Statement

OOZOU is committed to conducting business ethically and in compliance with all applicable anti-bribery and anti-corruption laws and regulations. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships.

2. Purpose and Scope

This Anti-Bribery and Anti-Corruption (ABAC) Policy establishes OOZOU's standards and guidelines to prevent bribery and corruption in our business operations. This policy applies to all OOZOU employees, directors, officers, contractors, consultants, and any third parties acting on our behalf.

3. Definitions

Bribery: Offering, promising, giving, accepting, or soliciting an advantage as an inducement for an action which is illegal, unethical, or a breach of trust. Inducements can take the form of gifts, loans, fees, rewards, or other advantages.

Corruption: The abuse of entrusted power for private gain.

Facilitation Payments: Small payments made to secure or expedite the performance of a routine or necessary action to which the payer has legal or other entitlement.

4. Prohibited Conduct

The following conduct is prohibited under this policy:

  • Offering, promising, or giving a bribe to any person.
  • Requesting, agreeing to receive, or accepting a bribe from any person.
  • Making facilitation payments.
  • Engaging in any activity that might lead to a breach of this policy.
  • Threatening or retaliating against another person who has refused to commit a bribery offense or who has raised concerns under this policy.

5. Gifts and Hospitality

OOZOU recognizes that giving and receiving modest gifts or hospitality can be a legitimate contribution to building good business relationships. However, all gifts and hospitality should be:

  • Reasonable and proportionate in value.
  • Given in good faith and not intended to influence business decisions improperly.
  • Compliant with local laws and customs.
  • Transparent and properly recorded.
  • Not given or received during active tender or bidding processes.

6. Due Diligence

OOZOU will conduct appropriate due diligence on third parties with whom we do business to ensure they share our commitment to anti-bribery and anti-corruption. This may include background checks, requesting anti-corruption policies, and including anti-bribery clauses in contracts.

7. Reporting Violations

All employees and associated persons are encouraged to report any concerns or suspicions regarding potential violations of this policy. Reports can be made to:

Email: compliance@oozou.com

OOZOU prohibits retaliation against anyone who reports violations of this policy in good faith.

8. Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, up to and including termination of employment or business relationship. Violations may also result in criminal or civil penalties for the individuals involved and for OOZOU.

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