Anti-Bribery & Corruption Policy

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1. Introduction

This Anti-Bribery & Corruption Policy ("Policy") sets forth the guidelines and principles that govern the conduct of all employees, contractors, and agents of A3 Revenues (referred to as "the Company") in relation to anti-bribery and anti-corruption matters. The Company is committed to conducting its business ethically and maintaining the highest standards of integrity, transparency, and compliance with all applicable laws and regulations, including the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other relevant anti-bribery and anti-corruption laws.

2. Policy Scope

This Policy applies to all employees, contractors, agents, consultants, and any other individuals acting on behalf of the Company (collectively referred to as "Covered Parties"). It applies to all business activities conducted by the Company, including its operations in Tel Aviv, Israel, and its global presence, specifically in Europe, America, Asia, and Africa.

3. Prohibition of Bribery and Corruption

3.1 Bribery

The Company strictly prohibits any form of bribery, whether direct or indirect, in any business dealings. Covered Parties shall not offer, promise, give, authorize, solicit, or accept bribes, kickbacks, facilitation payments, or any other improper advantages to or from any individual, organization, or government entity, whether in the public or private sector, for the purpose of influencing or obtaining business or gaining an improper advantage.

3.2 Corruption

The Company is committed to maintaining a zero-tolerance stance towards corruption. Covered Parties must not engage in any corrupt practices, including embezzlement, extortion, fraud, or any other illegal or unethical conduct that undermines the integrity of the Company's operations or business relationships.

4. Gifts, Hospitality, and Entertainment

4.1 Business Courtesies

Covered Parties may offer or accept reasonable and proportionate business courtesies, such as gifts, hospitality, or entertainment, as long as they are consistent with customary business practices, of a nominal value, and do not create any appearance of impropriety or compromise the integrity of the Company or the recipient. All such courtesies must be disclosed and recorded in accordance with the Company's internal policies and procedures.

4.2 Government Officials and Public Servants

When interacting with government officials or public servants, Covered Parties should exercise extra caution and strictly adhere to the applicable laws and regulations governing such relationships. Gifts, hospitality, or entertainment provided to government officials or public servants should be strictly limited to those that are legal, transparent, and directly related to legitimate business purposes.

5. Due Diligence and Third-Party Relationships

The Company shall exercise due diligence when entering into relationships with third parties, including but not limited to suppliers, agents, distributors, consultants, and joint venture partners. Prior to engaging in business dealings, Covered Parties must conduct appropriate risk assessments and ensure that the third parties adhere to high ethical standards, comply with applicable laws and regulations, and are committed to preventing bribery and corruption.

6. Reporting and Whistleblowing

6.1 Reporting Suspicious Conduct

Covered Parties have a responsibility to promptly report any actual or suspected breaches of this Policy or any incidents of bribery or corruption. Reports can be made to a designated ethics hotline, compliance officer, or any other designated internal channels. The Company guarantees confidentiality and non-retaliation for individuals reporting in good faith.

6.2 Investigations and Corrective Actions

Upon receipt of a report or discovery of a potential violation, the Company will conduct a thorough investigation and take appropriate disciplinary action against any Covered Party found to be in breach of this Policy. Corrective measures may include disciplinary actions, termination of employment or business relationship, and, if warranted, reporting to the relevant authorities