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Anti-Corruption Policy

Last updated: September 14, 2025

This policy statement sets out OMADUDU N.V.’s stance on combating corruption. OMADUDU N.V. aims to operate ethically and complies with all applicable anti-corruption laws, both domestically and internationally.

Article 1. Scope

This policy applies to:

  • Article 1.1 All employees, managers, and directors of OMADUDU N.V.
  • Article 1.2 All external parties acting on behalf of OMADUDU N.V. (suppliers, consultants, subcontractors, partners)
  • Article 1.3 All entities within the OMADUDU N.V. group and its service lines

Article 2. Prohibited Conduct

OMADUDU N.V. enforces a zero-tolerance approach to corruption. Prohibited conduct includes, but is not limited to:

  • Article 2.1 Offering, giving, receiving, or soliciting bribes
  • Article 2.2 Facilitating payments (payments to expedite routine actions)
  • Article 2.3 Undisclosed kickbacks or opaque commissions
  • Article 2.4 Undue influence on decision-making through improper benefits
  • Article 2.5 Use of intermediaries to conceal illicit conduct

Article 3. Gifts, Hospitality and Sponsorship

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

  • Article 3.1 Are of nominal value
  • Article 3.2 Are not frequent
  • Article 3.3 Are transparent and reported in advance to the Compliance Officer

Sponsorships and donations must be approved in writing in advance and must not serve hidden commercial purposes.

Article 4. Reporting and Whistleblowing

Employees and external parties are required to promptly report suspected corruption or unethical conduct via:

  • Article 4.1 Email: [email protected]
  • Article 4.2 The internal reporting portal
  • Article 4.3 OMADUDU N.V. guarantees protection against retaliation for good-faith reporters. All reports are handled confidentially and investigated by the Compliance team.

Article 5. Enforcement and Sanctions

Violations of this policy may result in:

  • Article 5.1 Internal disciplinary action
  • Article 5.2 Termination of employment or contract
  • Article 5.3 Criminal prosecution
  • Article 5.4 Civil liability
  • Article 5.5 OMADUDU N.V. reserves the right to terminate relationships with external parties immediately in case of policy breaches.

Article 6. Responsibilities

  • Article 6.1 Board / Executive Management: Overall responsibility for policy implementation and enforcement
  • Article 6.2 Compliance Officer: Monitors compliance, manages reports, provides advice
  • Article 6.3 Managers: Act as role models and communicate the policy within their teams
  • Article 6.4 Employees and Third Parties: Required to comply and to cooperate with investigations

Article 7. Review and Amendments

This policy is reviewed annually and amended as necessary. Changes are communicated through internal channels and take effect after executive approval.

Article 8. Related Documents

  • Article 8.1 Code of Ethics
  • Article 8.2 Privacy Statement
  • Article 8.3 MSP™ Terms & Conditions
  • Article 8.4 Master Services Agreement
  • Article 8.5 CyberShield™ and CyberGuard™ Terms & Conditions

Versioning & Changelog

Version 2.0.1 — 14 September 2025

  • Legal restructuring and harmonization
  • Addition of reporting procedures and sanctions
  • Integration with Code of Ethics and MSP™ Terms