Effective Date: July 17th, 2026
SupportFinity Inc. (“SupportFinity” or the “Company”) has zero tolerance for bribery and corruption in any form, anywhere we do business. We win business on the quality of our platform and services, never through improper payments or favors.
This Policy sets the rules everyone acting for SupportFinity must follow. It is designed to comply with U.S. anti-corruption law and with the laws of every country where we operate. Where local law or a customer contract sets a stricter rule, the stricter rule applies.
This Policy applies to everyone who works for or on behalf of SupportFinity, in every country:
Everyone covered is called a “Covered Person.” The Policy covers dealings with government officials and with private companies and individuals alike.
SupportFinity is a Delaware corporation based in San Francisco, California. Covered Persons must comply with all anti-corruption laws that apply to our business, including:
| Law | What it prohibits |
|---|---|
| U.S. Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1 et seq. | Offering or paying anything of value to a foreign official to obtain or keep business or gain an improper advantage |
| U.S. federal bribery statute, 18 U.S.C. § 201 | Bribes and illegal gratuities to U.S. federal officials |
| U.S. Travel Act, 18 U.S.C. § 1952 | Commercial (private-sector) bribery that violates state law, using interstate or foreign travel or communications |
| U.S. mail and wire fraud statutes, 18 U.S.C. §§ 1341, 1343, 1346 | Schemes that deprive others of honest services, including kickbacks |
| State laws, including California Penal Code § 641.3 | Commercial bribery of employees or agents of private companies |
| Local laws where we operate or sell | For example, the UK Bribery Act 2010, the Saudi Anti-Bribery Law and the Egyptian Penal Code |
Violations can bring criminal fines, imprisonment for individuals, civil penalties, loss of contracts and serious harm to our reputation. Fines imposed on an individual may not be paid by the Company where the law forbids it.
Covered Persons must never, directly or through anyone else:
No business goal justifies breaking this Policy. SupportFinity will accept losing a deal rather than win it improperly, and no one will be penalized for refusing to pay a bribe.
SupportFinity prohibits facilitation payments, even where local law or the FCPA might allow them.
The only exception is a payment demanded under an imminent threat to someone’s health, safety or liberty. If that happens, pay only what is needed to stay safe, then report it to the Compliance Officer within 24 hours so it can be recorded accurately.
Modest courtesies that build normal business relationships are allowed if they are reasonable, transparent and never tied to a decision. Every gift or hospitality must be:
| Situation | Rule |
|---|---|
| Gift or meal to a private-sector contact, up to $100 per person per occasion and $250 per person per year | Allowed, record it |
| Above those limits | Written pre-approval from the Compliance Officer |
| Anything of value to a Government Official, including employees of state-owned companies | Written pre-approval from the Compliance Officer, in every case |
| Paying travel or lodging for a customer or official | Written pre-approval; pay vendors directly, never give per-diem cash; no family members or side trips |
| Gifts received by Covered Persons above $100 | Decline politely, or report to the Compliance Officer |
Dealing with governments and state-owned companies carries the highest risk, because the FCPA treats their employees as Government Officials. Some of our customers and prospects are state-owned or state-linked, so this section applies to everyday sales work.
SupportFinity can be held liable for bribes paid by Third Parties acting for us. Before engaging any referral partner, reseller, agent, advisor or revenue-share partner, we will:
Every Third Party agreement must include clauses that the Third Party will comply with this Policy and all applicable anti-corruption laws, keep accurate records, allow SupportFinity to audit those records, certify compliance on request, and accept immediate termination, with no further payments due, for any breach.
Red flags that must be reported before any payment: requests for cash, unusual upfront or success fees, payments to an offshore or unrelated account, a partner recommended by a Government Official, refusal to sign anti-corruption terms, vague invoices, or a partner with no real experience in the work.
Every payment, expense, gift, discount and fee must be recorded accurately, in reasonable detail and on time. SupportFinity follows the standard set by the FCPA’s accounting provisions as good practice.
Covered Persons must disclose to the Compliance Officer, in writing and before acting, any personal interest that could affect a Company decision. This includes a financial interest in a customer, supplier or partner, a family member working for one, or outside work for a company that does business with SupportFinity.
Advisors and partners who are employed elsewhere must follow their employer’s conflict rules, obtain any required approval or waiver, and must not receive personal benefit from deals with their own employer unless that employer has approved it in writing.
Before acquiring a business, investing in one or forming a joint venture, SupportFinity will carry out anti-corruption due diligence on the target or partner. After closing, the acquired business or joint venture must adopt this Policy, or an equivalent one, and train its people within 90 days.
Anyone who suspects a breach of this Policy must report it promptly. Ask before acting if you are unsure.
The Compliance Officer will review every report promptly and may appoint outside counsel to investigate. Covered Persons must cooperate fully and must never destroy or alter relevant records.
Breaking this Policy, failing to report a known breach, or retaliating against someone who reports, may lead to disciplinary action up to and including termination of employment, termination of any advisory, contractor or partner agreement, recovery of losses, and referral to law enforcement. SupportFinity may withhold or claw back any commission, revenue share or equity tied to business obtained in breach of this Policy, to the extent the law and the relevant agreement allow.
Approved by: Moe Nada, Founder & Chief Executive Officer, SupportFinity Inc.