RELAYTO Anti-Bribery Policy

Anti-Bribery Policy Introduction RELAYTOiscommittedtoconductingbusiness in an ethical and lawful manner. This Anti-Bribery Policy outlines the company’s stance against bribery and corruption. 1. Definition of Bribery ● Bribery involves offering, giving, receiving, or soliciting something of value to influence a decision or action. 2. Prohibition of Bribery ● Employeesmustnotengageinanyformofbribery,whetherdirect or indirect. ● Thisincludes bribing public officials, clients, or any other third parties. 3. Gifts and Hospitality ● Gifts and hospitality must be reasonable, proportional, and for legitimate business purposes. ● Lavishorinappropriate gifts and hospitality are prohibited. 4. Third-Party Relationships ● Thirdparties acting on behalf of RELAYTO must comply with this Anti-Bribery Policy. ● Duediligence should be conducted before engaging third parties. 5. Record Keeping ● Accurateandcompleterecords of all transactions must be maintained. ● Falseormisleading records are strictly prohibited. 6. Reporting and Whistleblowing ● Employeesareencouragedtoreportanysuspectedbribery or corruption. ● Reportscanbemadeconfidentially and without fear of retaliation. 7. Training and Communication ● Employeeswill receive regular training on anti-bribery laws and this policy. ● Thispolicy will be communicated to all employees and relevant third parties.

8. Disciplinary Actions ● Violations of this policy may result in disciplinary actions, including termination of employment. ● Legalactions may be taken against employees or third parties involved in bribery. 9. Additional details are found in RELAYTO’s MSP here. Conclusion Byadhering to this Employee Code of Conduct and Anti-Bribery Policy, RELAYTO aims to foster atransparent, ethical, and lawful working environment. All employees are expected to uphold these standards in their daily activities.