Anti Corruption and Bribery Policy

Last updated: May 2025 

Introduction

Morphis AI seeks to develop responsible and transparent business practices and is also committed to strict internal standards to avoid any acts or signs of corruption or bribery. This policy establishes Morphis’s commitment to ethical conduct and compliance with anti-corruption and anti-bribery laws, particularly relevant to the IT industry, where transparency, data integrity, and responsible vendor relationships are critical.

Fundamental Principles

This policy guides our actions and strategic decisions, ensuring that we operate in an ethical and sustainable manner, benefiting our employees, customers, partners and society as a whole.

Guiding Principles:

  • To comply with, and exceed where practicable, all applicable legislation, regulations and codes of practice regarding this matter.
  • To ensure that all staff are fully aware of our anti-corruption and anti-bribery Policy and are committed to implementing and improving it.
  • This applies to all employees, executives, contractors, consultants, and third-party vendors globally, including software developers, sales teams, support staff, and IT service providers.
  • To review, periodic report, and to continually strive to improve our anti-corruption and anti-bribery performance.
 

Main Guidelines

Morphis AI and associated companies will make every effort to maintain this policy in force and follow the good practices included therein.

Definitions

  • Bribery: Offering or receiving anything of value to improperly influence a business or technical decision.
  • Corruption: Misuse of power or access (e.g., data, systems, procurement) for per- sonal or company gain.
  • Facilitation Payments: Prohibited small payments to speed up routine IT-related approvals or services.

Roles and Responsabilities

Custom Table
Role Responsability
CIO Oversee implementation and enforcement of this policy. Evaluates technical controls and monitors third-party access.
Policy & Procedures Committee Provides oversight and guidance on third-party risk management practices, policies, and procedures.
Legal Reviews contracts and ensures compliance with regulatory requirements.
Business Units Manage day-to-day interactions with third parties and report issues.
All Morphis Stakeholders Responsible for registering and reporting any failure or incident according to this document.

Policy Statement

Morphis AI maintains a zero-tolerance policy for bribery and corruption. This includes:

  • No bribery in software licensing, procurement, or client onboarding.

  • No unethical influence in government or enterprise IT contracts.

  • It is considered improper conduct offering, promising, giving, requesting, agree-ing to receive or accepting a bribe, including facilitation of payment

    The restrictions described apply to all forms of bribery and corruption, all negotiations and all business relationships and transactions in with Morphis Tech or any affiliate company is part, in order to obtain or maintain any advantage of any kind for the benefit of the company or any other person or entity.

Third-party Monitoring

All vendors, resellers, cloud service providers, and consultants must:

  • Undergo compliance screening as necessary.

  • Be aware of possible anti-bribery clauses in contracts.

  • Be monitored for ethical conduct whenever justified

Reporting and Whistleblowing

Employees must report suspicious behaviour, including:

  • Unusual vendor pricing or contract terms.
  • Requests for unofficial payments or data access.

 

Compliance and Enforcement

Non-compliance with this policy may result in disciplinary action, including termination of contracts, removal from approved vendor lists, and referral to regulatory authorities for further investigation. All employees are required to adhere to this policy and report any violations or concerns to their supervisor, CIO or the PPC (Policy & Procedures Committee).

Where illegal activities or theft of company property (physical or intellectual) are suspected, the company may report such activities to the legal authorities.

Periodic awareness is mandatory for:

✓ Sales and procurement teams.
✓ Technical staff handling sensitive data or systems. ✓ Executives and managers.

Policy Reviews and Updates

This policy shall be reviewed annually upon major regulatory or operational changes in the IT sector or as needed to ensure alignment with regulatory requirements, industry best practices, and changes in the business environment.

Updates and revisions to this policy shall be approved by the Board of Directors or PPC (Policy & Procedures Committee).

Policy Comunication

This policy shall be communicated to all employees, third-party vendors, and relevant stakeholders through appropriate channels, such as employee handbooks, websites, training programs, and vendor contracts. Employees, clients and vendors are required to acknowledge their understanding and compliance with this policy upon engagement with Morphis Tech or any of its affiliates.

Commitment and Responsability

All employees, managers, and partners of Morphis AI are responsible for adhering to this policy and actively contributing to the company’s anti-corruption and anti-bribery efforts.

Senior management is committed to providing the necessary resources for the effective implementation of this policy and ensuring those efforts is an integral part of the organizational culture.

Together, we can build a more ethical and responsible future.

Contact

If you have more questions about this Policy, please contact us.