U2xAI Compliance & Business Ethics Policy

(Anti-Corruption, Commissions, Gifts, and Entertainment)

1. Purpose

U2xAI is committed to conducting all business ethically, transparently, and in full compliance with applicable anti-corruption, anti-bribery, and business conduct laws worldwide. This policy establishes standards to prevent corruption, ensure fair business practices, and protect the integrity of our operations.

2. Scope

This policy applies to:

  • All U2xAI employees, contractors, officers, and directors.

  • Any third parties representing U2xAI (agents, consultants, distributors, resellers).

  • All business activities, whether domestic or international.

3. Anti-Corruption & Bribery

  • Zero Tolerance: U2xAI strictly prohibits offering, promising, authorizing, or giving anything of value (including payments, gifts, or favors) to Government Officials or private sector representatives to improperly influence a business decision.

  • Government Officials: Includes any elected or appointed official, employee of a state-owned enterprise, political candidate, or their relatives.

  • Facilitation Payments: U2xAI does not permit “grease” or facilitation payments, even where considered customary.

4. Business Ethics Standards

  • Integrity First: All business dealings must be fair, honest, and free from manipulation or improper advantage.

  • Conflict of Interest: Employees must disclose any situation where personal interests could conflict with U2xAI’s interests.

  • Transparency: All financial transactions must be accurately recorded in company books in accordance with accounting standards.

5. Payment of Commissions & Third Parties

  • Due Diligence: U2xAI will conduct background checks and compliance reviews before engaging agents, distributors, or consultants.

  • Written Contracts: All agreements must clearly define services provided and payment terms.

  • No Improper Payments: Commissions, success fees, or consulting payments may not be used as a vehicle for bribes or kickbacks.

6. Gifts, Hospitality, and Entertainment

  • Permissible: Reasonable, modest, and infrequent gifts or hospitality that are customary and legal in the local market.

  • Prohibited: Lavish, excessive, or frequent gifts that may appear intended to influence decisions.

  • Government Officials: Gifts or entertainment involving Government Officials require prior written approval from U2xAI Compliance.

  • Disclosure: All gifts and entertainment must be logged and approved in accordance with company procedure.

7. Training & Awareness

  • All employees and third parties must complete mandatory compliance training annually.

  • Regular refreshers and case study workshops will be conducted to reinforce ethical decision-making.

8. Reporting & Whistleblowing

  • Employees must immediately report suspected violations to the Compliance Officer or via the anonymous Ethics Hotline.

  • U2xAI prohibits retaliation against employees who report concerns in good faith.

9. Enforcement & Consequences

  • Violations of this policy may result in disciplinary action, up to and including termination, as well as civil or criminal liability.

  • Third-party violations may result in termination of business relationships.

10. Governance

  • Compliance Oversight: The U2xAI Compliance Committee monitors implementation and effectiveness.

  • Review: This policy will be reviewed annually and updated as required to reflect changes in law or business practice.