Anti-Bribery and Corruption Policy

Aperim Pty Ltd (ABN 46150699737; ACN 150699737) is incorporated in New South Wales, Australia and operates the aicial brand. In this policy, “aicial” refers to that brand; “we”, “us” and “our” refer to Aperim Pty Ltd; and “you” refers to a reader of this policy, including anyone who works for us or acts on aicial’s behalf.

We do not offer, give, solicit or accept a bribe, kickback or other improper payment or advantage to obtain or retain business, or to obtain any other improper advantage, in connection with aicial’s business. This applies whether the conduct happens directly or through a third party acting on our behalf, such as a referral or affiliate partner under our Reseller and Partner Program Agreement, or a reseller partner under a separate reseller agreement with us.

This policy applies to everyone who works for us, including our employees and contractors, and to anyone else who acts on aicial’s behalf, including a reseller or affiliate partner. It applies wherever we or they do business.

This policy covers:

• a cash or in-kind payment;
• a gift or hospitality that goes beyond what is reasonable and proportionate in the ordinary course of business;
• a facilitation payment — a small, unofficial payment to a public official to speed up or secure a routine action they are already obliged to perform; and
• a political or charitable contribution made to improperly influence a business decision.

Each of these is covered whether it is offered, given, solicited or accepted directly, or through a third party acting on our behalf. We do not make facilitation payments, even where they are locally customary.

Australia is our home market, and the United Kingdom, the United States, mainland China, India, Spain and France are aicial’s other current and target markets. Our commitments in this policy are designed to meet or exceed the anti-bribery and anti-corruption laws that apply in each of those markets, including Australia’s foreign bribery offence under Division 70 of the Criminal Code (Schedule to the Criminal Code Act 1995 (Cth)), the UK Bribery Act 2010, and the US Foreign Corrupt Practices Act. We do not attempt to set out the detail of each law here. Instead, we hold ourselves to the highest applicable standard, consistent with the Ethics Charter commitment reflected in our Responsible AI Usage Policy: where law and our own ethics point in different directions, we choose the more protective course.

If you know or reasonably suspect a breach of this policy, tell us. Email compliance@aicial.com, or raise it under our Whistleblower and Ethics Policy.

We treat a breach of this policy seriously. It may result in disciplinary action, up to and including termination of employment or engagement, and, for a reseller or affiliate partner, termination of the relationship, including under our Reseller and Partner Program Agreement. We report a breach to the relevant law enforcement or regulatory authority where the law requires it, and we may do so where we judge it necessary.

Aperim Pty Ltd, which operates aicial, is an early-stage company. Accountability for this policy currently sits with Aperim Pty Ltd’s leadership rather than a separate or formally constituted compliance function.

As aicial grows, we commit to formalising anti-bribery governance, including clearer internal roles, a defined approval process for higher-risk gifts, hospitality and third-party engagements, and regular reporting, proportionate to that growth, and to updating this policy when we do.

We review this policy at least annually, and sooner if our business, the law or good practice changes in a way that affects it. The version, effective date and last-reviewed date shown at the top of this policy identify the current version.

We publish an updated policy on our website and, where a change is material, give additional notice through an appropriate channel, including to our reseller and affiliate partners.

For questions about this policy, or to raise a concern under it, contact:

Aperim Pty Ltd, which operates the aicial brand
ABN 46150699737
ACN 150699737
New South Wales, Australia
Email: compliance@aicial.com