Policy Statement

Shopspray maintains a zero-tolerance stance toward all forms of bribery and corruption. We are committed to conducting business with the highest level of integrity and complying with all applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

Prohibited Actions

Employees, partners, and representatives of Shopspray are strictly prohibited from:

• Bribery: Offering, promising, or giving anything of value (cash, gifts, or favors) to any individual—whether a government official or a private sector partner—to gain an improper business advantage.
• Facilitation Payments: Making “grease” payments to expedite routine government actions (e.g., permits or customs), regardless of local custom.
• Kickbacks: Accepting or providing payments in exchange for business favors or contracts.

Gifts, Hospitality, and Expenses

• Reasonableness: Gifts and hospitality must be modest, infrequent, and directly related to a legitimate business purpose.
• Pre-approval: Any gift or hospitality intended for a government official requires prior written approval from the Compliance Officer.
• Cash Prohibitions: Under no circumstances are cash or cash equivalents (e.g., gift cards or vouchers) to be given or received.

Third-Party Management

Because Shopspray can be held liable for the actions of its partners, we apply a risk-based due diligence process to all technology partners, distributors, and consultants.

• All third-party contracts must include standard anti-corruption clauses.
• No payment shall be made to a third party if there is a reason to believe it may be used for a bribe.

Digital Integrity & AI

As of 2025, Shopspray prohibits the use of AI tools or automated systems to manipulate data, bypass internal controls, or engage in deceptive practices that could facilitate corruption.

Reporting and Non-Retaliation

If you suspect a violation of this policy, you must report it immediately through:

• Your direct manager or Human Resources.
• The Shopspray Integrity Hotline.

Shopspray will not tolerate retaliation against any individual who reports a concern in good faith or refuses to participate in a corrupt act.

Consequences of Non-Compliance

Violating this policy is a serious offense. Failure to comply may result in disciplinary action up to termination of employment and may also lead to civil or criminal penalties under international law.

Approved by: Søren Handlos, CEO, Co-founder
Effective Date: January 2025