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Anti-bribery and Corruption Policy for Avecto Representatives

It is Avecto's policy to conduct all of our business in an honest and ethical manner. Avecto takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships and implementing and enforcing effective systems to counter bribery and corruption.

Avecto Limited and all of its affiliated companies worldwide ("Avecto"), requires its channel partners (for example, resellers, original equipment manufacturers, distributors, alliance partners), suppliers, vendors, consultants and any other third-party representative (collectively, "Avecto Representatives") to comply with this Anti-Bribery and Corruption Policy. Avecto has a separate and comprehensive anti-bribery and corruption policy for our employees, staff, officers and directors and which is included in the Avecto Handbook.

Avecto prohibits corruption of government officials and the payments of bribes or kickbacks of any kind, including facilitation payments, whether in dealings with public officials or individuals in the private sector. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Avecto is committed to observing the standards of conduct set forth in the United States Foreign Corrupt Practices Act ("FCPA"), the UK Anti-Bribery Act 2010 (“BA”) together all applicable anti-corruption and anti-money laundering laws of the countries in which we and/or the Avecto Representatives operate.

In this Policy, "Government Official" refers to all of the following: (i) any employee of a government entity or subdivision, including elected officials; (ii) any private person acting on behalf of a government entity, even if just temporarily; (iii) officers and employees of companies that are owned or controlled by the government; (iv) candidates for political office; (v) political party officials; and (vi) officers, employees and representatives of public international organizations, such as the World Bank and United Nations. Representatives should be aware that in certain countries and in certain industries, an individual who seems to work for a private entity might be considered a Government Official.

Compliance with Anti-Bribery and Corruption Laws

Each Avecto Representative shall conduct itself with high ethical standards and comply with all applicable anti-corruption laws, including the FCPA and BA. No Avecto Representative shall, directly or indirectly, promise, authorize, offer or pay anything of value (including but not limited to gifts, travel, hospitality, charitable donations or employment) to any government official or other person to improperly influence any act or decision of such official for the purpose of promoting the business interests of Avecto or the Avecto Representative in any respect, or to otherwise improperly promote the business interests of Avecto or the Avecto Representative in any respect.

Prohibition on Bribes

No Avecto Representative shall pay or offer to pay a bribe, or provide another thing of value for obtaining an improper benefit, to any third party, public or private.

Facilitation payments and kickbacks

Avecto prohibits bribes of any kind, including facilitation payments. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the US or UK, but are common in some other jurisdictions.

Money Laundering Prohibited

No Avecto Representative shall use its relationship with Avecto to disguise or attempt to disguise the sources of illegally obtained funds.

Political and Charitable Donations

Avecto Representatives must not circumvent this Policy by making political or charitable donations to indirectly impact the outcome of a business transaction, including obtaining or retaining business.

Accurate Books and Records

Representatives must record payments and other compensation in their corporate books, records and accounts in a timely manner and in reasonable detail. No undisclosed or unrecorded accounts may be established for any purpose. False, misleading, incomplete, inaccurate or artificial entries in the books and records are prohibited. Personal funds may not be used to accomplish what is otherwise prohibited by this and other Avecto policies.

No Retaliation

Avecto will not tolerate retaliation against anyone who has, in good faith, reported a possible violation of this Policy or refused to participate in activities that violate this Policy.

Enforcement

In addition to its rights and remedies under applicable agreements, Avecto may refer any Representative who violates this policy to U.K., U.S. or foreign authorities for criminal prosecution or other enforcement action, or bring suit for damages.

Reporting

Representatives should report any concerns about violation of this policy or applicable laws to their legal department and/or their ethics and compliance officer. Representatives should also report to Avecto through Rachel Cunliffe, Finance Director at Rachel.Cunliffe@Avecto.com