# Anti-Corruption & Ethics Policy \[inference labs] This policy applies to all employees, officers, directors, contractors, agents, and any third parties acting on behalf of Inference Labs Inc. (the “Company”). Compliance with this policy is a condition of engagement with the Company. **1. Commitment to Ethical Business Conduct** Inference Labs Inc. is committed to conducting business with integrity, transparency, and in full compliance with all applicable laws and regulations. The Company maintains a zero-tolerance policy toward bribery, corruption, and unethical business conduct in any form, regardless of geography or business context. **2. Anti-Bribery and Anti-Corruption** No employee, officer, contractor, or representative of the Company may directly or indirectly offer, promise, give, request, or accept any bribe, kickback, or improper payment to or from any person or entity, including government officials, customers, suppliers, or business partners. The Company complies with all applicable anti-corruption and anti-bribery laws, including: * [Corruption of Foreign Public Officials Act (Canada)](https://laws-lois.justice.gc.ca/eng/acts/c-45.2/page-1.html) * [Criminal Code of Canada](https://laws-lois.justice.gc.ca/eng/acts/C-46/page-1.html) * [Foreign Corrupt Practices Act (USA)](https://www.justice.gov/criminal/criminal-fraud/foreign-corrupt-practices-act) * [UK Bribery Act 2010](https://www.legislation.gov.uk/ukpga/2010/23/pdfs/ukpga_20100023_en.pdf) **3. Government Officials** For purposes of this policy, “government official” means any officer or employee of a government, government-owned or government-controlled entity, public international organization, or any person acting in an official capacity on behalf of any such entity. This includes employees of state-owned enterprises and officials of political parties. Interactions with government officials must comply with all applicable anti-corruption laws. Employees and representatives may not provide gifts, payments, or any other benefits intended to improperly influence a government decision or action. **4. Gifts and Business Hospitality** Reasonable and customary business expenses are permitted in connection with legitimate business activities, provided they are not intended to improperly influence business decisions and comply with applicable laws and this policy. Gifts or hospitality that are excessive in value, provided in cash, or offered in connection with a pending business decision are prohibited. **5. Conflicts of Interest** Employees and representatives must avoid situations where personal interests conflict, or could reasonably appear to conflict, with the interests of the Company. Examples include: * Holding a financial interest in a competitor, supplier, or customer without disclosure * Engaging in outside employment or consulting that competes with or compromises duties to the Company * Using Company resources, information, or relationships for personal gain * Participating in decisions where a personal relationship with a vendor or partner could influence the outcome Actual or potential conflicts of interest must be disclosed promptly to Company leadership. The Company will determine on a case-by-case basis whether a conflict exists and what steps, if any, are required to mitigate it. **6. Commissions and Third-Party Payments** Any commissions, referral fees, or third-party compensation arrangements must be supported by written agreements, reflect fair market value for legitimate services rendered, and comply with applicable laws. Such payments must never be used to facilitate improper or unlawful conduct. Due diligence should be conducted on third parties before entering into such arrangements. **7. Political Contributions** Company funds, assets, or resources may not be used to make contributions to political parties, candidates, or campaigns without prior written approval from Company leadership and in compliance with applicable laws. This policy does not restrict employees from making personal political contributions in their individual capacity. **8. Accurate Records** The Company maintains accurate books, records, and financial documentation. All transactions must be recorded honestly and reflect their true business purpose. No false, misleading, or incomplete entries shall be made in the Company’s records for any reason. **9. Reporting and Enforcement** Employees and representatives are expected to report suspected violations of this policy promptly to Inference Labs Inc. leadership or the designated compliance contact. Reports may be made confidentially where permitted by law. Retaliation against any individual who reports concerns in good faith will not be tolerated and may itself constitute grounds for disciplinary action. Violations of this policy may result in disciplinary action up to and including immediate termination of employment or engagement, and may be referred to the appropriate legal or regulatory authorities. **10. Training and Acknowledgement** All employees and relevant contractors are expected to read, understand, and comply with this policy. The Company will provide training on this policy as appropriate. Employees may be required to acknowledge in writing that they have received, read, and understood this policy. **11. Ongoing Compliance and Review** Inference Labs Inc. will review and update this policy annually, or more frequently as required to ensure continued compliance with applicable laws and evolving business practices. The current version of this policy will be maintained and made available to all relevant parties. **Questions and Compliance Contact** For questions regarding this policy, to report a concern, or to request guidance, please contact: Compliance Contact: Inference Labs Inc. | [www.inferencelabs.com](http://www.inferencelabs.com)