Objective:

AMAZE is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. It is Amaze policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, in all of its operations, of not engaging in bribery or corruption.

Scope and applicability:                  

This Anti-Bribery and Anti-Corruption Policy applies to all individuals working for all affiliates and subsidiaries of Amaze at all levels and grades, including directors, senior executives, officers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers, volunteers, interns, agents, or any other person associated with Amaze.

In this Policy, “Third Party(ies)” means any individual or organization, who / which come into contact with Amaze or transact with Amaze and also includes actual and potential clients, suppliers, business contacts, consultants, intermediaries, representatives, subcontractors, agents, advisers, joint ventures and government & public bodies (including their advisers, representatives and officials, politicians and political parties).

Definition:

Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage. Bribery and corruption can take many forms, including the provision or acceptance of:

• Cash payments;
• Phony jobs or “consulting” relationships;
• Kickbacks;
• Political contributions;
• Charitable contributions;
• Social benefits; or
• Gifts, travel, hospitality, and reimbursement of expenses.

Policy requirements:

AMAZE employees and agents are strictly prohibited from offering, paying, promising, or authorizing:

• Any payment or other thing of value;
• To any person;
• Directly or indirectly through or to a third party;
• For the purpose of (i.e., in exchange for);
• Causing the person to act or fail to act in violation of a legal duty;
• Causing the person to abuse or misuse their position; or
• Securing an improper advantage, contract or concession;
• For Amaze or any other party.

To promote compliance with anti-corruption laws in UAE and other applicable jurisdictions, no Amaze employee shall undertake any Improper Payment Activity in respect of a foreign official, a domestic official, or a person doing business in the private sector.

In addition, Amaze books and records must correctly record both the amount and a written description of any transaction. Amaze employee must ensure that there is a reasonable

relationship between the substance of a transaction and how it is described in the Company’s books and records.

It is contemplated that Amaze will institute detailed procedures and standards related to training, due diligence, the recording of transactions, and other areas, to implement the terms of this Policy. In particular, Amaze will institute standards and procedures for:

• Sponsoring travel of government or government officials;
• Direct and in-kind support for government or government officials;
• Security support for public law enforcement;
• Per diems for government officials;
• Agreements with government-affiliated third parties, including those who may interact with the government on Amaze behalf or benefit;
• Contracting with state-owned entities;
• Meals, gifts, and entertainment for government officials;
• Charitable and cultural donations to government or government officials, or to those parties affiliated with them; and Political contributions.

Audits:

Audits of Amaze offices, operating units, and contractors may be conducted periodically to ensure that the requirements of this Policy and applicable procedures and guidelines are being met. Audits may be conducted internally by Amaze, or externally by retained third parties. Audit documentation shall include performance improvement action plans.

Correlation with other Corporate Policies:

Other Amaze policies impacted by, and which should be construed consistent with this Policy, include the Code of Conduct with Escalation Procedure, Standard of Business Conduct, Procedures for Implementing the Anti-Bribery and Anti-Corruption Policy, the Vendor On-Boarding Standard and the Supplier Code of Ethics.

Waiver:

There is no permitted deviation or waiver from this Policy.

Discipline:

Any employee who violates the terms of this Policy will be subject to disciplinary action. Any employee who has direct knowledge of potential violations of this Policy but fails to report such potential violations to Company management will be subject to disciplinary action. Any employee who misleads or hinders investigators inquiring into potential violations of this Policy will be subject to disciplinary action. In all cases, disciplinary action may include termination of employment. Any third-party agent who violates the terms of this Policy, who knows of and fails to report to Amaze management potential violations of this Policy, or who misleads investigators making inquiries into potential violations of this Policy, may have their contracts re-evaluated or terminated