Anti-Bribery, Corruption and Fraud Policy and Procedures

1. Policy Statement

AIMES LAB FOR COMPUTER SYSTEMS & COMMUNICATION EQUIPMENT SOFTWARE DESIGN CO. L.L.C. (“AIMES,” “Company”) recognizes that the prevention of fraud, bribery, and corruption is integral to good governance and affirms its commitment to conduct business and operations in an honest and ethical manner. AIMES operates internationally — including in the United States, the European Union, and the Middle East, through its Bishop product (https://bishop.aimestech.com) — and is committed to ensuring transparency and integrity in all business dealings and relationships wherever it operates, and to implementing effective systems and procedures for the prevention, detection of, and action against fraud, bribery, and corruption.

AIMES adopts a zero-tolerance approach to fraud, bribery, corruption, and facilitation payments in its business activities and operations. In line with best practice, appropriate preventive and punitive action, including prosecution as permitted under applicable law, will be taken against violations. All AIMES employees are responsible for preventing and reporting fraud, bribery, and corruption. All stakeholders — including customers, partners, suppliers, contractors, and temporary staff, and organizations with which AIMES conducts business — are expected to abide by this Policy.

2. Legal Framework

This Policy is designed to ensure compliance with, at minimum:

• The UAE Federal Decree-Law No. 31 of 2021 on the Issuance of the Crimes and Penalties Law (which repealed and replaced the former Penal Code, Federal Law No. 3 of 1987), including its provisions on bribery of public officials, embezzlement, and breach of trust (UAE Legislation);
• The UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as amended by Federal Decree-Law No. 26 of 2021 (“UAE AML/CFT Law”) (UAE Legislation; Central Bank of the UAE);
• The UAE Federal Decree-Law No. 36 of 2023 Regarding the Regulation of Competition, which replaced Federal Law No. 4 of 2012 with effect from 29 December 2023 (“UAE Competition Law”) (UAE Legislation; Lexology summary);
• The U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”), which applies extraterritorially to conduct connected to U.S. persons, U.S.-listed entities, or the use of U.S. financial systems, including in connection with AIMES’s provision of the Services to U.S.-based customers;
• The UK Bribery Act 2010, which imposes extraterritorial liability, including the “failure to prevent bribery” corporate offence, on organizations that carry on business or part of a business in the UK (legislation.gov.uk);
• Applicable EU Member State anti-corruption laws and the OECD Anti-Bribery Convention, relevant to AIMES’s EU-based customers, personnel, and infrastructure (including data hosting in Finland); and
• Applicable anti-bribery and anti-money-laundering laws of other Middle East jurisdictions in which AIMES or its customers operate.

Where these frameworks impose differing standards, AIMES applies the most stringent applicable standard across its global operations.

3. Definitions

Bribery means offering, promising, giving, receiving, or soliciting anything of value (money, gifts, favors, or other advantage) to influence the actions of an official or any other person in return for performing or refraining from performing an act in breach of a duty, or to improperly obtain or retain business or a business advantage. This includes bribery of foreign public officials, which is separately prohibited under the FCPA and UK Bribery Act regardless of where the conduct occurs.

Facilitation Payment means a payment made to a public, private, or government official to expedite or secure the performance of a routine governmental action to which the payer is already entitled. Facilitation payments are prohibited under this Policy, without exception, consistent with the position under the UK Bribery Act and current FCPA enforcement guidance.

Corruption means dishonesty by a person entrusted with a position of authority to acquire an improper personal or organizational benefit, including offering, giving, or accepting inducements, gifts, favors, or benefits-in-kind that may influence a person’s actions, whether or not any direct loss results.

Money Laundering means concealing or disguising the origin of funds derived from criminal activity (such as fraud, tax evasion, corruption, or drug trafficking) by moving them through legitimate business channels to make them appear lawful.

4. Gifts, Hospitality and Third-Party Due Diligence

• Modest, reasonable, and transparent gifts or hospitality connected to legitimate business purposes may be permitted where properly recorded, but must never be offered or accepted where they could reasonably be perceived as intended to improperly influence a business or regulatory decision.
• Employees must not give or accept cash or cash-equivalent gifts under any circumstances.
• AIMES performs risk-based due diligence on third parties (including resellers, consultants, and agents acting on AIMES’s behalf) prior to engagement and periodically thereafter, particularly where the third party interacts with government officials or operates in a jurisdiction with elevated corruption risk.
• All third parties acting on AIMES’s behalf are contractually required to comply with anti-bribery and anti-corruption standards no less stringent than this Policy.

5. Detection, Reporting and Whistleblower Protection

Incidents of fraud, bribery, or corruption may be detected through periodic audits by an independent, registered auditor, by the UAE Accountability Authority where it conducts an audit, or by managers, supervisors, colleagues, customers, or any other person who becomes aware of such conduct.

Any person may report suspected fraud, bribery, or corruption in good faith to support@aimestech.com or through any other channel designated by AIMES from time to time. AIMES prohibits retaliation against any individual who reports a concern in good faith, even if the concern is later not substantiated.

6. Disciplinary and Legal Consequences

Appropriate disciplinary action will be taken in proportion to the seriousness of the incident, in compliance with applicable internal regulations and employment law. Where warranted, AIMES may pursue criminal referral or civil action under Federal Decree-Law No. 31 of 2021, the FCPA, the UK Bribery Act, or other applicable law, and may terminate business relationships with any third party found to have violated this Policy.

7. Anti-Money Laundering and Combating Terrorism Financing Policy

AIMES is committed to preventing money laundering and terrorism financing by any individual, business, or company using AIMES’s facilities, in compliance with the UAE AML/CFT Law and applicable Emirate of Dubai laws, as well as relevant EU anti-money-laundering directives and U.S. Bank Secrecy Act principles where AIMES’s customer base or payment flows touch those jurisdictions.

AIMES personnel must not engage in any business relationship with a third party that appears suspicious or might facilitate money laundering. Red flags include (without limitation): undisclosed beneficial ownership; requests for or offers of cash payment; contradictory information from a counterparty; unusual or opaque corporate structures; transactions inconsistent with a customer’s known business profile; and use of the Services in a manner inconsistent with its intended professional, decision-support purpose.

Suspicious transactions must be reported to the concerned authorities as required under the UAE AML/CFT Law and Emirate of Dubai law. AIMES will apply risk-based customer due diligence, maintain relevant records, provide training to concerned employees, and review and amend this section periodically to reflect legal and regulatory developments.

8. Health, Safety and Environment

AIMES is committed to protecting the health and safety of people and the environment. AIMES expects partners, customers, contractors, and employees to operate in an environmentally responsible manner, comply with applicable environmental laws and regulations, obtain and maintain any required environmental permits or licenses, and minimize waste of energy, water, and other resources.

9. Conflict of Interest

AIMES requires that employees avoid engaging in, or appearing to engage in, any activity involving an actual or reasonably foreseeable conflict between their personal interests and AIMES’s interests. Employees must not allow financial, employment, or other personal interests to compromise the impartiality of decisions made for AIMES, and must put AIMES’s interests ahead of personal interests when conducting AIMES’s business. Any doubt as to whether a situation constitutes a conflict of interest must be raised promptly with AIMES management.

Customers, partners, suppliers, and contractors should not employ an individual who remains, during that employment, an AIMES employee, and should not make undisclosed payments to AIMES personnel in connection with the award of work. Friendships and family relationships outside the course of business are normal and acceptable; however, any personal relationship that could affect, or appear to affect, AIMES’s business dealings must be disclosed to AIMES.

10. Anti-Trust and Competition Compliance

AIMES supports free and fair competition and deals with all parties independently and impartially. AIMES personnel must comply with the UAE Federal Decree-Law No. 36 of 2023 Regarding the Regulation of Competition, which prohibits (among other things) price fixing, market sharing, exchange of commercially sensitive information with competitors, abuse of a dominant market position (including exploitation of economic dependency and predatory pricing), and participation in meetings, conferences, or committees that could have an anti-competitive effect. Where AIMES conducts business in the EU or U.S., personnel must also comply with applicable EU competition law (Articles 101–102 TFEU) and U.S. antitrust law (including the Sherman Act), applying the most stringent applicable standard.

11. Training and Policy Review

AIMES will provide periodic training to relevant employees on this Policy and will review and update this Policy at least annually, or upon a material change in applicable law, to ensure continued compliance across the United States, European Union, United Arab Emirates, and other Middle East jurisdictions in which AIMES operates.

12. Contact

Questions or reports relating to this Policy may be directed to support@aimestech.com.