# Anti-Bribery and Anti-Corruption Policy Datafalk Inc. and Parallax 84 SAS · Adopted by resolution of the Board of Directors of Datafalk Inc. and by decision of the President of Parallax 84 SAS · Effective date: 26 October 2026 ## 1. Our commitment Datafalk Inc. and the companies of its group that adopt this Policy (together, "Datafalk") conduct business honestly and without bribery or corruption of any kind. Datafalk does not tolerate bribery, whether of public officials or of private persons, whether direct or through third parties, anywhere in the world, and whatever the commercial consequences of refusing to pay a bribe. Datafalk's business is to help organisations see and manage risk in their supply chains, including corruption risk; our own conduct must meet the standard we help our customers apply. ## 2. Scope This Policy applies to the directors, officers and employees of each adopting company. It applies to contractors, consultants, freelancers, distributors, agents, resellers and other persons acting for or on behalf of Datafalk (together with directors, officers and employees, "Datafalk Personnel") through the compliance clause included in their contracts. Breach of this Policy by a third party is grounds for termination of its relationship with Datafalk, in accordance with its contract and applicable law. ## 3. Applicable laws Datafalk Inc., as a corporation organised under the laws of a State of the United States, is subject to the anti-bribery provisions of the United States Foreign Corrupt Practices Act applicable to domestic concerns. Datafalk's activities may also be subject to the United Kingdom Bribery Act 2010, to the French Code pénal and to the French law of 9 December 2016 ("Sapin II"), and to the anti-corruption laws of every country in which Datafalk operates, each according to its own scope. This Policy sets a single standard designed to satisfy each of these laws, including the keeping of accurate books and records and the prohibition of facilitation payments, which Datafalk adopts as internal rules whether or not a given law imposes them on it; where a law imposes a stricter requirement, that requirement applies. ## 4. Definitions "Bribe" means anything of value offered, promised, given, requested, agreed to be received or accepted, directly or indirectly, with the intention of improperly influencing a decision, obtaining or retaining business or an advantage, or rewarding improper performance. "Anything of value" includes cash and cash equivalents, gifts, hospitality, travel, employment or internships, donations, loans, discounts, favours and business opportunities. "Public official" means any officer, employee or representative of a government, public body, state-owned or state-controlled entity, public international organisation or political party, any candidate for office, and any person acting in an official capacity for them, including employees of public research organisations and agencies. ## 5. Prohibited conduct Datafalk Personnel shall not: (a) offer, promise, give or authorise a bribe; (b) request, agree to receive or accept a bribe; (c) make facilitation payments, meaning small payments to secure or expedite a routine action by a public official, even where local custom tolerates them; (d) use a third party to do anything that this Policy prohibits; (e) conceal, mischaracterise or fail to record any payment, gift or expense. ## 6. Gifts, hospitality and entertainment 6.1 Modest gifts and hospitality given or received in the ordinary course of business are permitted where they are reasonable in value and frequency, given openly, not in cash or cash equivalent, not intended to influence a decision, not offered during a tender or negotiation, and consistent with the policies of the recipient's organisation. 6.2 Any gift, meal or hospitality with a value above USD 250 per person, any travel or accommodation, and anything offered to or received from a public official require the prior written approval of the Compliance Officer and are recorded in the gifts and hospitality register. Related benefits are aggregated and may not be split to avoid approval. The threshold is an internal approval trigger, not an amount deemed lawful. The Compliance Officer may not approve a benefit concerning himself; such requests are submitted to another director. ## 7. Public officials and public customers Datafalk works with public bodies, research organisations and agencies. Datafalk Personnel shall take particular care in those relationships: no gift or hospitality other than of nominal value, no payment or benefit to an official or a relative of an official, and no engagement of an official or a former official as a consultant without the Compliance Officer's prior written approval, taking into account the rules of the official's own organisation. ## 8. Third parties Before engaging a distributor, reseller, agent, consultant or other intermediary who will interact with customers or public officials on Datafalk's behalf, Datafalk performs proportionate due diligence on its reputation, ownership and qualifications, documents the business rationale and the remuneration, and includes in the contract an obligation to comply with this Policy, a right of audit and a right of termination for breach. Payments to third parties must be commensurate with the services rendered, made to the contracting entity in its country of operation and properly documented; any request for payment to another account or country is referred to the Compliance Officer. ## 9. Charitable and political contributions Datafalk does not make political contributions. Charitable contributions and sponsorships require the Compliance Officer's prior approval and must not be made to obtain a business advantage. ## 10. Conflicts of interest Datafalk Personnel shall disclose to the Compliance Officer any personal, financial or family interest that could influence, or appear to influence, a decision taken for Datafalk, and shall abstain from that decision. A conflict concerning the Compliance Officer is disclosed to another director. ## 11. Books and records Datafalk keeps accurate and complete books and records that fairly reflect all transactions and dispositions of assets, and maintains internal controls proportionate to its size designed to prevent and detect improper payments. No undisclosed or unrecorded account or fund may be established for any purpose. ## 12. Reporting and non-retaliation Any person who suspects a breach of this Policy may report it to the Compliance Officer at ethics@datafalk.com or by post to the address of Datafalk Inc., or, where the Compliance Officer is concerned, to another director of Datafalk Inc. Reports may be made anonymously by post; reports made by email are treated confidentially, and information is shared only with the persons who need it for a fair investigation and for compliance with the law. Datafalk investigates reports promptly, informs the person implicated of the allegations in a manner that preserves the investigation, and prohibits retaliation against anyone who reports a concern in good faith or cooperates with an investigation, whatever the outcome. Nothing in this Policy prevents anyone from reporting to a public authority or restricts the protections granted to whistleblowers by law. Personal data processed in the handling of reports is used only for that purpose and is kept for the duration of the investigation and the applicable limitation period. ## 13. Training and attestation Datafalk Personnel receive this Policy when they join and acknowledge it in writing. Those exposed to public officials, procurement or third-party intermediaries receive specific guidance. The Compliance Officer records distributions, acknowledgements, approvals and exceptions. ## 14. Consequences of breach Breach of this Policy may expose the individual and Datafalk to criminal and civil liability. Datafalk treats any breach as a serious matter that may result in disciplinary action up to and including dismissal, in accordance with the applicable procedure and law, in termination of the contract with the third party concerned, and in referral to the authorities. ## 15. Ownership and review The Compliance Officer is Louis Ramard, Chief Executive Officer of Datafalk Inc. Matters concerning the Compliance Officer are handled by another director of Datafalk Inc. The Board of Directors of Datafalk Inc. adopts this Policy by resolution and reviews it at least annually; each other adopting company adopts it by decision of its legal representative.