Anti-Bribery and Corruption Policy

1. Introduction and Policy Statement

MissionOpsAI Ltd (company registration number 14437210) operates a zero-tolerance policy towards bribery and corruption in all its forms. This policy is made pursuant to section 7 of the Bribery Act 2010, which creates a corporate offence of failing to prevent bribery. Compliance with this policy is mandatory for all directors, employees, contractors, and agents acting on behalf of the Company.

Bribery is the offering, promising, giving, accepting, or soliciting of a financial or other advantage as an inducement or reward for improper conduct. It is illegal under the Bribery Act 2010 and is contrary to our values as a company. Corruption more broadly encompasses fraud, abuse of position, and other forms of dishonest conduct. We will not tolerate any such behaviour regardless of the circumstances, competitive pressure, or potential commercial benefit.

2. Scope

This policy applies to all individuals working for or on behalf of MissionOpsAI Ltd, including all directors, employees, workers, consultants, contractors, agents, and any other person acting in a representative capacity for the Company. It applies to conduct in the United Kingdom and overseas.

The prohibition on bribery applies equally to bribing officials in the public sector (including public servants, officials of public bodies, and officers of foreign governments) and to commercial bribery in the private sector.

3. What Constitutes Bribery

Bribery includes the following types of conduct:

• Offering, promising, or giving a payment, gift, or hospitality to a third party to induce them to perform their duties improperly or to reward them for having done so.
• Requesting, agreeing to receive, or accepting a payment, gift, or hospitality from a third party that you know or suspect is offered with the intention of influencing your conduct.
• Directing or authorising another person to engage in conduct that would constitute bribery.
• Using a third party (such as an agent or intermediary) to pay a bribe on the Company's behalf.

4. Gifts and Hospitality

Not all gifts and hospitality are improper. Reasonable and proportionate gifts and hospitality, offered and received in a transparent manner and in the ordinary course of business, are permissible provided they are not intended or likely to influence a business decision improperly.

The following rules apply to gifts and hospitality:

• All gifts received from or given to third parties must be recorded in a gifts and hospitality register maintained by the Company.
• Gifts of a value exceeding £50 may not be accepted without prior approval from the CEO.
• Gifts in cash or cash equivalents (including vouchers) may not be accepted or given in any amount.
• Hospitality must be reasonable, transparent, and consistent with normal business practice in the relevant sector.
• Gifts and hospitality must never be offered or accepted in connection with a pending commercial or procurement decision.
• All entertainment expenses must be recorded with full details of attendees and business purpose.

5. Facilitation Payments

Facilitation payments are small, unofficial payments made to government officials or public servants to speed up or secure routine government actions (such as issuing permits, processing paperwork, or providing services to which the payer is already entitled). Such payments are illegal under the Bribery Act 2010 regardless of their size.

We strictly prohibit the making of facilitation payments. If you are ever pressured to make a facilitation payment in the course of business conducted on behalf of the Company, you must refuse and report the incident immediately as set out in Section 7 of this policy.

6. Due Diligence on Third Parties

We carry out proportionate due diligence on agents, intermediaries, and business partners, particularly those who may interact with public officials or operate in higher-risk jurisdictions. Due diligence includes review of the third party's anti-bribery policies, their reputation, and the nature of any payments proposed.

Our standard terms with agents and business partners include appropriate anti-bribery warranties and a right of termination in the event of a breach of anti-bribery obligations.

7. Reporting Concerns

If you suspect or become aware of any conduct that may constitute bribery or corruption, you must report it promptly. Reports can be made to the CEO directly or, where the concern involves the CEO, to an appropriate legal adviser.

Reports can be made in confidence to legal@missionopsai.com. We are committed to protecting anyone who raises a genuine concern in good faith from retaliation. Victimisation of a person who raises a concern in good faith is itself a disciplinary matter.

8. Training

All new employees and contractors working with us will receive anti-bribery training as part of their onboarding. The key principles of this policy will be communicated to all relevant personnel annually. Training records are maintained by the Company.

9. Consequences of Breach

Any employee who breaches this policy will face disciplinary action, which may include summary dismissal for gross misconduct. We reserve the right to report suspected criminal conduct to the relevant authorities, including the National Crime Agency and the Serious Fraud Office.

Contractors, agents, and other third parties who breach this policy or any applicable anti-bribery warranty will have their engagement terminated immediately.