Business Ethics, Anti-Bribery & Corruption, Anti-Money Laundering, and Prevention of the Facilitation of Tax Evasion Policy

1. Introduction

Codemagic ("the Company") is committed to conducting business with the highest ethical standards and in full compliance with all applicable laws and regulations. This policy sets out the principles and guidelines to ensure compliance with laws related to anti-bribery and corruption, anti-money laundering, and the prevention of tax evasion facilitation.

2. Scope

This policy applies to all employees, directors, officers, contractors, consultants, agents, suppliers, and any third parties acting on behalf of the Company (collectively referred to as "Personnel").

3. Business Ethics

The Company expects all Personnel to uphold integrity, honesty, transparency, and accountability in all business dealings. Any unethical behavior, including fraud, dishonesty, or conflicts of interest, is strictly prohibited.

4. Anti-Bribery and Corruption

4.1 Prohibition of Bribery

The Company strictly prohibits the offering, giving, receiving, or soliciting of bribes, kickbacks, or any improper payments in any form.

Gifts, hospitality, or entertainment must not be used to influence business decisions improperly.

4.2 Facilitation Payments

Facilitation payments, which are small payments made to expedite routine government actions, are strictly prohibited.

5. Anti-Money Laundering (AML)

5.1 Prohibition of Money Laundering

The Company is committed to preventing money laundering and ensuring that its services are not used to disguise the proceeds of crime. Unusual or suspicious transactions must be reported to the CEO.

6. Prevention of the Facilitation of Tax Evasion

6.1 Zero Tolerance for Tax Evasion

The Company prohibits the facilitation of tax evasion, including assisting or encouraging third parties to evade tax.

7. Reporting and Compliance

7.1 Reporting Violations

Personnel are required to report any suspected violations of this policy to their manager or the CEO.

The Company prohibits retaliation against anyone who reports concerns in good faith.

7.2 Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, including termination of employment or contractual agreements.

The Company may also report violations to the relevant authorities where necessary.