Anti-Bribery & Anti-Corruption Statement

Zero-Tolerance Policy

Circuit Labs Inc maintains a strict zero-tolerance policy toward bribery and corruption in all its forms. We are committed to conducting business with integrity, transparency, and in compliance with all applicable anti-bribery and anti-corruption laws.

Prohibited Conduct

The following conduct is strictly prohibited:

• Offering, promising, giving, or accepting bribes in any form
• Making facilitation payments to expedite routine government actions
• Using third parties to make payments that would be prohibited if made directly
• Engaging in any form of corrupt conduct to obtain or retain business

Gifts and Hospitality

Gifts and hospitality must be reasonable, proportionate, and not intended to influence business decisions. All gifts and hospitality above nominal value must be recorded and approved in accordance with our internal policies.

Third-Party Due Diligence

We conduct appropriate due diligence on third parties, including agents, consultants, and business partners, to assess corruption risks before entering into business relationships.

Record Keeping

We maintain accurate and complete financial records and internal controls to prevent and detect bribery and corruption. All transactions must be properly recorded and documented.

Reporting

Anyone who suspects bribery or corruption should report their concerns through our contact channels. We are committed to investigating all reports promptly and confidentially.

Whistleblower Protection

We prohibit retaliation against anyone who reports suspected bribery or corruption in good faith. Whistleblowers will be protected from adverse employment consequences for making good-faith reports.