Effective Date: January 2026
1. Purpose and Commitment
Greenwing AI Incorporated (“Greenwing,” “we,” “our,” or “the Company”) is committed to conducting its business ethically, transparently, and in full compliance with all applicable anti-corruption and anti-bribery laws and regulations worldwide.
Greenwing maintains a zero-tolerance policy for bribery, corruption, improper payments or benefits, or unethical conduct of any kind, whether involving government officials or private counterparties.
2. Scope and Applicability
This Policy applies to:
• All Greenwing employees, officers, and directors
• Contractors, consultants, and temporary personnel
• Agents, intermediaries, resellers, and business partners acting on Greenwing’s behalf
Compliance with this Policy is a condition of employment, engagement, or association with Greenwing.
3. Applicable Laws
Greenwing complies with all applicable anti-corruption laws, including but not limited to:
• The U.S. Foreign Corrupt Practices Act (FCPA)
• The UK Bribery Act
• Anti-corruption laws in all jurisdictions where Greenwing operates or does business
Where laws differ, the stricter standard applies.
4. Prohibition on Bribery and Improper Payments
Greenwing strictly prohibits:
• Offering, promising, authorizing, or providing anything of value to:
◦ Government officials
◦ Political parties or candidates
◦ Employees of state-owned or state-controlled entities
◦ Private individuals or companies
for the purpose of influencing actions, securing improper advantages, or retaining business
• Indirect payments made through third parties, agents, or intermediaries
• Facilitation payments are strictly prohibited, even where local law or custom might permit them
“Anything of value” includes cash, gifts, travel, meals, entertainment, favors, employment opportunities, data access, or other benefits.
5. Definition of “Government Official”
For purposes of this Policy, “government official” broadly includes:
• Employees or officials of any government agency, department, or ministry
• Employees of state-owned enterprises, state-controlled entities, or sovereign wealth funds
• Political party officials, candidates for public office, or their staff
• Employees of public international organizations (UN, World Bank, etc.)
• Members of royal families acting in official capacity
• Any person acting in an official governmental capacity
This definition applies regardless of rank or authority level. When uncertain whether someone qualifies as a government official, treat them as such and seek compliance guidance.
6. Gifts, Hospitality, and Business Courtesies
Reasonable, infrequent, and transparent business courtesies may be permitted only if they:
• Are lawful under applicable local law
• Do not exceed USD $75 per person per occasion
• Do not exceed USD $300 annually per business relationship
• Are not cash or cash equivalents
• Are not intended to influence decisions improperly
• Are modest in value and appropriate to the business context
• Are accurately recorded in Company books and records
Gifts or hospitality involving government officials require prior written approval from Company leadership or designated compliance personnel.
7. Third Parties and Business Partners
Greenwing may be held responsible for corrupt actions taken by third parties acting on its behalf.
Accordingly:
• Third parties must be vetted using risk-based due diligence before engagement
• High-risk third parties (including government intermediaries, consultants in high-corruption jurisdictions, or agents with significant government interaction) require enhanced due diligence and ongoing monitoring
• Third-party compensation must be commercially reasonable and commensurate with services actually provided
• Contracts must include anti-corruption representations, warranties, and audit rights
• Greenwing reserves the right to terminate relationships immediately for violations of this Policy
8. Books, Records, and Internal Controls
Greenwing maintains accurate books, records, and accounts that:
• Fairly reflect all transactions and dispositions of assets in reasonable detail
• Prohibit off-book accounts, unrecorded funds, or false entries
• Require appropriate supporting documentation for all payments
• Require dual approval for payments to third parties
• Support internal controls designed to prevent and detect improper conduct
9. Political Contributions and Charitable Donations
Greenwing does not make political contributions on behalf of the Company unless expressly approved by senior leadership and permitted by law.
Employees’ personal political activities and contributions are permitted but must not suggest Company endorsement or support.
Charitable donations or sponsorships must:
• Serve a legitimate charitable purpose
• Not be used as a conduit for bribery or influence
• Be properly documented and approved in advance
10. Reporting and Compliance
Employees and partners are expected to:
• Promptly report suspected violations through:
◦ Direct supervisor or designated compliance officer
◦ Email: mailto:[email protected]
• Cooperate fully with internal reviews or investigations
• Raise concerns without fear of retaliation
All reports will be investigated promptly and handled confidentially to the extent possible.
Retaliation against individuals who report concerns in good faith is strictly prohibited.
11. Violations and Enforcement
Violations of this Policy may result in:
• Disciplinary action, up to and including termination
• Contract termination
• Referral to law enforcement where appropriate
Greenwing takes compliance seriously and enforces this Policy consistently.
12. Training and Certification
All employees and covered third parties must:
• Complete anti-corruption training upon hire/engagement and annually thereafter
• Certify compliance with this Policy in writing
• Maintain records of training completion
Training content and frequency may be adjusted based on role and risk exposure.
13. Questions and Policy Administration
Questions regarding this Policy or its application should be directed to: mailto:[email protected] or Company leadership.
Greenwing may update this Policy periodically to reflect legal, regulatory, or operational changes. Employees will be notified of material updates.