# Anti-Bribery, Corruption, and Financial Crime (ABC & AML) Policy **Last Updated:** October 28, 2024 **1. Purpose and Scope** Eloquent AI is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all business dealings. This policy sets out our zero-tolerance approach to bribery, corruption, money laundering, tax evasion, and any other form of financial crime. It applies to: - Eloquent AI Inc. (United States) and Eloquent AI Ltd. (United Kingdom) - All directors, officers, employees, contractors, consultants, and suppliers acting on behalf of the company anywhere in the world. **2. Definitions** - **Bribery:** Offering, giving, receiving, or soliciting something of value to influence an action or decision improperly. - **Corruption:** Abuse of entrusted power for private gain. - **Money Laundering:** Concealing or disguising the origins of funds obtained from illegal activity. - **Facilitation Payments:** Unofficial or small payments made to secure or expedite routine actions, these are prohibited. - **Criminal Finance Offence:** Failure to prevent the facilitation of tax evasion under the UK Criminal Finances Act 2017. **3. Legal Framework** This policy aligns with: - UK Bribery Act 2010 - UK Criminal Finances Act 2017 - US Foreign Corrupt Practices Act (FCPA) - US Bank Secrecy Act and Anti-Money Laundering laws - Applicable EU and international anti-corruption conventions **4. Policy Statement** Eloquent AI prohibits all forms of bribery, corruption, money laundering, and facilitation of tax evasion. We will: - Conduct business transparently, fairly, and in compliance with law. - Reject improper gifts, payments, or inducements. - Ensure accurate and complete financial record-keeping. - Maintain effective systems to detect and prevent financial crime. - Require equivalent standards from all business partners and third parties. **5. Responsibilities** - **Leadership and Management:** The leadership team is responsible for promoting a culture of integrity and ensuring that adequate controls, reporting mechanisms, and reviews are in place. - **Employees and Contractors:** Everyone working for or with Eloquent AI must: - Avoid any activity that might lead to, or suggest, bribery or corruption. - Report immediately any suspicion of financial crime or unethical conduct. - Complete any required compliance or due-diligence checks before engaging with clients, vendors, or intermediaries. - **Suppliers and Partners:** Suppliers must maintain ethical standards, comply with all applicable anti-bribery and AML laws, and cooperate with Eloquent AI’s due-diligence processes. **6. Gifts, Hospitality, and Entertainment** Gifts and hospitality may only be offered or accepted if they: - Are reasonable, proportionate, and infrequent; - Are given openly and transparently; and - Cannot be perceived as an attempt to influence a business decision. Cash or cash equivalents (e.g. gift cards) must never be offered or accepted. Any gifts or hospitality that might exceed local norms must be disclosed to the _designated compliance contact_ for approval. **7. Preventing Money Laundering and Tax Evasion** Eloquent AI will not engage in or facilitate money laundering, terrorist financing, or tax evasion. To mitigate risk, the company will: - Conduct reasonable checks on clients, suppliers, and partners. - Monitor financial transactions for unusual or suspicious activity. - Escalate any suspicion of money laundering or criminal finance to the _designated compliance contact_ immediately. Employees are prohibited from concealing, transferring, or converting funds known or suspected to be derived from criminal activity. **8. Record-Keeping and Controls** Eloquent AI maintains accurate financial records consistent with its accounting and audit controls. All payments, invoices, and expenses must be properly authorised and supported by appropriate documentation. Falsifying records or making off-book payments is strictly prohibited. **9. Reporting Concerns** Employees and partners must report any suspected breach of this policy to the _designated compliance contact_ or via established internal channels. Reports will be handled confidentially and without retaliation. Confirmed breaches may result in disciplinary action, termination, or referral to law-enforcement authorities. **10. Training and Awareness** Eloquent AI will provide periodic training and awareness materials to ensure employees understand how to recognise and prevent bribery, corruption, and financial crime in their roles. **11. Continuous Improvement** This policy will be reviewed annually and updated as required to reflect evolving legal obligations, operational risks, or best-practice standards. **Approved by:** Tugce Bulut, Chief Executive Officer, Dr Aldo Lipani, Chief AI & Innovation Officer