Everwall's Anti-Bribery Policy

Last Updated: March 20th, 2023

Everwall, Inc. (“Everwall”) is committed to conducting business in an ethical and lawful manner, and to preventing bribery, corruption, or other improper payments to any person or entity. This anti-bribery policy sets out the standards of conduct that Everwall expects from all of its employees, contractors, agents, and other persons who act on behalf of Everwall.

PROHIBITION OF BRIBERY AND CORRUPTION

Everwall prohibits the offering, giving, solicitation, or acceptance of any bribe, kickback, or improper payment in any form, whether in cash, gifts, services, or any other thing of value. Everwall requires all employees, contractors, agents, and other persons who act on behalf of Everwall to comply with all applicable laws, regulations, and industry standards related to bribery and corruption, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the OECD Anti-Bribery Convention.

FACILITATION PAYMENTS

Everwall prohibits any form of facilitation payments or any other payment that is made to secure or expedite routine government actions.

CONFLICT OF INTEREST

Everwall requires all employees, contractors, agents, and other persons who act on behalf of Everwall to conduct business in a transparent and honest manner, and to avoid any conflict of interest that may arise in connection with their work for Everwall.

REPORTING SUSPECTED OR ACTUAL BRIBERY OR CORRUPTION

Everwall requires all employees, contractors, agents, and other persons who act on behalf of Everwall to report any suspected or actual bribery, corruption, or other improper payments to their supervisor, manager, or the Legal Department.

NO RETALIATION

Everwall will not tolerate any retaliation against any employee, contractor, agent, or other person who reports suspected or actual bribery, corruption, or other improper payments.

CONSEQUENCES OF VIOLATIONS

Everwall reserves the right to terminate any employee, contractor, agent, or other person who violates this anti-bribery policy, or who fails to report any suspected or actual bribery, corruption, or other improper payments.

CONCLUSION

Compliance with this anti-bribery policy is mandatory for all employees, contractors, agents, and other persons who act on behalf of Everwall. Any violation of this policy may result in disciplinary action, including termination of employment or contractual relationship, and may also result in civil or criminal penalties.

This policy is a public statement of Everwall’s commitment to ethical and lawful business practices, and it is subject to review and update as necessary to ensure its continued effectiveness.