Anti-corruption policy

This anti-corruption policy sets forth Maxwer Group’s commitment to integrity, transparency and compliance with all applicable anti-corruption laws and regulations.

This policy applies to all employees, officers, directors, agents, contractors, and any other person acting on behalf of Maxwer Group, regardless of location or position.

PROHIBITED CONDUCT

We prohibit all forms of corruption, including but not limited to:

• Bribery: offering, promising or giving anything of value to improperly influence the actions of any person or entity or to obtain an improper advantage.
• Extortion: demanding, requesting or accepting anything of value in exchange for taking or refraining from taking any action or for obtaining an improper advantage.
• Fraud: knowingly misrepresenting, concealing or omitting material facts for the purpose of obtaining an improper advantage.
• Money laundering: engaging in any financial transaction with the intent to conceal the origin, destination or nature of illegally obtained funds.

COMPLIANCE REQUIREMENTS

All employees, officers, directors, agents, contractors, and any other person acting on behalf of Maxwer Group must comply with the following requirements:

• Adhere to all applicable anti-corruption laws and regulations.
• Refrain from engaging in any form of corruption and report any suspected or actual corruption to Maxwer Groups compliance officer.
• Maintain accurate and complete records of all business transactions and expenses and avoid the use of off-the-books accounts or payments.
• Obtain prior approval for any gifts, hospitality or other business courtesies provided to any person or entity.
• All third-party agents, consultants and contractors engaged by Maxwer Group are obliged to comply with the applicable laws and regulations related to anti-corruption.
• Participate in regular anti-corruption training and education programs to enhance awareness and understanding of this policy and related compliance requirements.

ENFORCEMENT AND SANCTIONS

Maxwer Group takes all allegations and reports of corruption seriously and will promptly investigate any suspected or actual corruption. Any employee, officer, director, agent, contractor, or any other person acting on behalf of our company found to have violated this anti-corruption policy or applicable laws and regulations may be subject to disciplinary action, up to and including termination of employment as well as civil or criminal proceedings.

Maxwer Group may amend this anti-corruption policy at any time and will communicate any changes to all employees, officers, directors, agents, contractors and any other person acting on behalf of Maxwer Group by publishing the police online.

This anti-corruption policy is intended to provide general guidance only and should not be construed as legal advice. For specific legal advice on anti-corruption compliance, please consult with qualified legal counsel.

This policy was last updated on March 31, 2023.