Posted: July 30, 2025

Effective: January 1, 2025 – December 31, 2025

Entities Covered: Digify Pte Ltd (Singapore) and Digify Inc. (United States)

1. Policy Statement

Digify enforces a zero-tolerance approach to bribery and corruption. We are committed to conducting business honestly, transparently, and in full compliance with all applicable anti-corruption laws, including:

• Singapore’s Prevention of Corruption Act
• U.S. Foreign Corrupt Practices Act (FCPA)
• UK Bribery Act 2010
• Australia’s Criminal Code Act 1995 (Cth)
• Relevant EU anti-corruption and corporate responsibility regulations

This policy applies globally to all employees, directors, officers, contractors, consultants, agents, and third-party representatives acting on behalf of Digify. Any violation may result in disciplinary action, including termination, and may trigger criminal liability for the individual.

2. Prohibited Conduct

You must not:

• Offer, promise, give, solicit, or accept bribes, kickbacks, or facilitation payments
• Attempt to improperly influence business decisions or government actions
• Provide or accept gifts, favors, hospitality, or services intended to secure an advantage
• Use your position at Digify for personal benefit or outside interests
• Engage a third party to do anything prohibited by this policy

3. Conflict of Interest

All employees must avoid situations where personal interests interfere—or appear to interfere—with Digify’s business decisions.

You must:

• Not engage in external work that conflicts with your role without prior written approval from the CEO
• Not use your position, access, or influence at Digify for personal gain
• Disclose in writing any personal or family relationships that may affect hiring, vendor selection, or other business matters
• Disclose and seek written approval for any potential conflict of interest

4. Gifts, Gratuities, and Hospitality

Gifts and hospitality may only be offered or accepted if they are:

• Infrequent, modest in value, and aligned with business norms
• Not intended to influence a decision or create a sense of obligation
• Compliant with applicable laws and Digify’s internal policies

✔ Permitted (with disclosure):

• Promotional items or small tokens (e.g., under SGD 30 / USD 20)
• Reasonable meals during business meetings
• Speaking engagement gifts (if appropriate and pre-approved)

✖ Strictly Prohibited:

• Cash, cash equivalents (e.g., gift cards)
• Luxury items, personal favors, or offers linked to decision-making
• Paid travel, accommodations, or entertainment unless pre-approved in writing by the CEO

Only the CEO may authorize corporate gifts or gestures for external relations. If you are unsure whether a gift or offer is appropriate, consult HR or your manager before taking action.

5. High-Risk Scenarios

Be especially cautious and seek approval when dealing with:

• Government officials or regulators
• Procurement, contracting, or tendering processes
• Third-party agents or resellers in high-risk jurisdictions
• Consultants or intermediaries where scope or deliverables are unclear

You must never offer anything of value to influence official decisions or gain unfair access to contracts.

6. Third Parties and Due Diligence

While Digify engages primarily with low-risk partners, any third party acting on our behalf must:

• Be vetted for legitimate business purposes
• Understand and comply with this policy
• Refrain from any form of bribery, corruption, or unethical practice

Due diligence will be applied where warranted, and Digify reserves the right to include anti-bribery clauses in contracts.

7. Record-Keeping

All transactions, payments, and gifts must be:

• Accurately recorded in Digify’s systems
• Fully supported by documentation
• Auditable, and never misleading or off-the-books

Augustine Lim

CEO
Digify Pte Ltd
Digify Inc.
20 December 2024