SUPPORTFINITY ANTI-BRIBERY & ANTI-CORRUPTION POLICY

Effective Date: July 17th, 2026

1. PURPOSE AND POLICY STATEMENT

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.

2. SCOPE

This Policy applies to everyone who works for or on behalf of SupportFinity, in every country:

• Directors, officers and employees, full-time, part-time or temporary
• Co-founders, advisors and consultants
• Contractors, freelancers and recruiters working on Company business
• Third parties acting for us, including referral partners, resellers, agents, distributors and revenue-share partners (together, “Third Parties”)

Everyone covered is called a “Covered Person.” The Policy covers dealings with government officials and with private companies and individuals alike.

3. APPLICABLE LAWS

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:

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.

4. DEFINITIONS

• Bribe: anything of value offered, promised, given, requested or accepted to improperly influence a decision, or to reward improper conduct.
• Anything of value: cash or cash equivalents (gift cards, vouchers), gifts, meals, entertainment, travel, jobs or internships, discounts, free services or software access, loans, donations, and favors to family members. There is no minimum amount.
• Government Official: any officer or employee of a government at any level, including employees of state-owned or state-controlled companies (for example, government-owned telecom, energy or banking groups), public international organizations, political parties and candidates, and anyone acting on their behalf.
• Kickback: a payment or benefit returned to someone in exchange for awarding business.
• Facilitation payment: a small unofficial payment to speed up a routine government action, such as issuing a permit or clearing customs.

5. PROHIBITED CONDUCT

Covered Persons must never, directly or through anyone else:

1. Offer, promise, give or authorize a bribe to anyone, whether a Government Official or a private person.
2. Request, agree to receive or accept a bribe or kickback.
3. Use a Third Party, family member or any other channel to do what this Policy forbids directly.
4. Make a payment knowing, or having reason to suspect, that part of it will be passed on as a bribe. Ignoring obvious warning signs is treated the same as knowing.
5. Hide, mislabel or falsely record any payment or benefit.

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.

6. FACILITATION PAYMENTS

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.

7. GIFTS, MEALS, HOSPITALITY AND TRAVEL

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:

• Given openly, not in secret, and in SupportFinity’s name
• Reasonable in value and frequency, and allowed by the recipient’s own rules
• Never cash or a cash equivalent
• Never offered during a tender, bid, negotiation or contract renewal with that party
• Recorded accurately in our expense records

8. GOVERNMENT OFFICIALS AND STATE-OWNED ENTITIES

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.

• Treat every employee of a state-owned or state-controlled customer as a Government Official.
• Get written pre-approval before giving them anything of value, however small.
• Follow public procurement rules exactly, including any ban on contact during a tender.
• Never hire, or promise to hire, an official or their relative to influence a decision. Any such hire needs Compliance Officer approval.
• Any request from an official for a payment, favor or donation must be refused and reported at once.

9. POLITICAL AND CHARITABLE CONTRIBUTIONS AND SPONSORSHIPS

• Political contributions: SupportFinity makes no political contributions anywhere, in cash or in kind, on the Company’s behalf. Covered Persons may take part in politics personally, on their own time and with their own money, without implying Company support.
• Charitable donations and sponsorships: allowed only with written pre-approval from the Compliance Officer, paid to a registered organization (never an individual), recorded accurately, and never requested by, or tied to, a customer or official with a pending decision.

10. THIRD PARTIES

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:

1. Check them: confirm identity, ownership, reputation and any links to Government Officials, scaled to the risk of the country and the deal.
2. Document a real need: a legitimate business reason for the engagement and fees that match the services provided.
3. Put it in writing: a written agreement that includes anti-corruption terms (below).
4. Pay properly: only by invoice, to a bank account in the Third Party’s own name in the country where they work, never in cash or to a third person.
5. Monitor: review their activity and re-check them at least once a year.

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.

11. BOOKS, RECORDS AND INTERNAL CONTROLS

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.

• No off-the-books accounts, cash funds or undisclosed side agreements.
• Expense claims need receipts and must name the recipients and the business purpose.
• Payments over $5,000 to Third Parties need approval from two authorized people, one of them outside the team requesting the payment.
• Records covered by this Policy are kept for at least five years.

12. CONFLICTS OF INTEREST

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.

13. MERGERS, ACQUISITIONS AND JOINT VENTURES

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.

14. TRAINING AND CERTIFICATION

• All employees, advisors and contractors receive anti-corruption training within 30 days of joining, and again every year.
• Sales, business development and finance staff, and anyone dealing with Government Officials, receive additional training on the higher-risk areas of this Policy.
• Each Covered Person confirms in writing that they have read this Policy when they join, and confirms compliance every year.
• Third Parties certify compliance when they sign their agreement and on request.

15. REPORTING CONCERNS AND NON-RETALIATION

Anyone who suspects a breach of this Policy must report it promptly. Ask before acting if you are unsure.

• How to report: to your manager, to the Compliance Officer, or by email to info@supportfinity.com. Reports may be made anonymously where local law allows.
• Confidentiality: reports are kept confidential and shared only with those who need to know to investigate.
• No retaliation: SupportFinity will not dismiss, demote, harass or otherwise penalize anyone who reports a concern in good faith or refuses to take part in bribery, even if it costs us business. Retaliation is itself a serious breach of this Policy.
• Your legal rights: nothing in this Policy stops anyone from reporting possible violations of law directly to a government agency, such as the U.S. Department of Justice or the Securities and Exchange Commission.

16. INVESTIGATIONS, VIOLATIONS AND DISCIPLINE

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.

17. GOVERNANCE AND REVIEW

• Owner: the Chief Executive Officer approves this Policy and appoints a Compliance Officer to run it day to day. Until another person is appointed, the CEO acts as Compliance Officer.
• Review: the Policy is reviewed at least once a year, and whenever the law or our business changes in a material way.
• Effective date: this Policy takes effect on 17 July 2026.

Approved by: Moe Nada, Founder & Chief Executive Officer, SupportFinity Inc.