Anti-Bribery & Anti-Corruption Policy

Anti-Bribery & Anti-Corruption Policy

Public policy · Approved for website publication

1. Purpose and Commitment

SpacePoint maintains zero tolerance for bribery, corruption, kickbacks and improper influence. We compete fairly and make decisions based on merit, quality, transparent criteria and lawful commercial considerations. This policy applies to directors, officers, employees, interns, contractors, instructors, agents and third parties acting for or representing SpacePoint.

2. Prohibited Conduct

No covered person may directly or indirectly offer, promise, authorize, request, accept or provide anything of value to improperly obtain or retain business, influence a decision, secure an unfair advantage, or reward improper conduct. This includes cash, gifts, entertainment, travel, employment opportunities, discounts, sponsorships, charitable contributions and benefits channeled through intermediaries.

3. Public Officials and Educational Institutions

Interactions with government agencies, public institutions, state-owned entities, schools, universities and procurement teams demand heightened care. No payment, benefit or advantage may be offered to influence official or procurement decisions. Any government-related hospitality or benefit must be lawful, transparent, modest and pre-approved where required.

4. Gifts, Hospitality and Expenses

Modest business courtesies may be permissible only when lawful, occasional, proportionate, openly recorded and not linked to a decision or tender. Cash and cash equivalents are forbidden. Team members must disclose gifts or hospitality that could create an appearance of influence. The company will establish and maintain internal monetary approval thresholds and a gifts register; until those are formally issued, seek written management approval before offering or accepting any material benefit.

5. Facilitation Payments and Third Parties

Facilitation payments are prohibited, even if described as customary, except where a person faces an immediate threat to health or safety; such circumstances must be reported promptly and documented. Business partners, resellers, agents and consultants must be vetted proportionately and may not be used to do indirectly what SpacePoint is prohibited from doing directly.

6. Procurement, Conflicts and Sponsorship

Supplier selection, sponsorship, recruitment, grants, awards and contract decisions must be fair and documented. Personal, family or financial conflicts of interest must be disclosed and managed. Sponsorships and charitable support must have legitimate purposes, be approved and properly recorded; they must not disguise improper payments.

7. Accurate Books and Records

All payments, discounts, reimbursements, gifts, donations and expenses must have genuine descriptions, appropriate supporting records and authorized approvals. False invoices, undisclosed funds, off-book accounts and misleading entries are prohibited.

8. Reporting and Non-Retaliation

Anyone who suspects bribery or corruption should use SpacePoint’s whistleblowing channel: [email protected]. SpacePoint prohibits retaliation against anyone raising a concern in good faith or cooperating in an investigation.

9. Review, Investigation and Consequences

Reports will be assessed impartially, with confidentiality maintained as far as practicable. Proven violations may result in corrective action, termination of engagement, recovery of losses or referral to competent authorities, consistent with applicable law. This policy is reviewed at least annually and following significant incidents.

Policy accountability and approval

Policy owner: SpacePoint management (designated policy owner to be assigned internally). Approved by: Abdullah AlSalmani, Co-Founder & CEO. Review cycle: At least annually or sooner if legal or operational requirements change.

Publication, Contacts and Approval

Approved by: Abdullah AlSalmani, Co-Founder & CEO, SpacePoint.

Publication date: 25 October 2026. Review: At least annually and when relevant legal or operational changes occur.

Primary contact: [email protected]. Secondary contact / escalation: [email protected].