Summary of Business Gifts, Anti-Corruption & Bribery Policy

Policy Statement:
Gate Technology FZE (“Company”, “we”, “us”, “our” or “ours”) is committed to conducting business in an honest and ethical manner. We have a zero-tolerance approach to bribery and corruption. As such, we have established a Business Gifts, Anti-Corruption & Bribery Policy (“Policy”) to observe and uphold the Company’s stance and provide guidelines to all relevant stakeholders.
The Policy applies to all jurisdictions where the Company operates.

Scope:
The Policy applies to all Employees, Board members, and Agents of the Company and covers all countries or territories where the Company operates.
“Employee”: means any and all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), trainees, seconded staff, home-workers, casual workers, volunteers, interns, or any other person associated with us, or any of our subsidiaries, affiliates or joint ventures.
“Board”: means the board of directors of the Company.
“Agent”: means any individual or organization that is appointed or authorized by the Company to act as its agent.

General Prohibition:
The Policy emphasizes that all forms of bribery and corruption, whether direct or indirect, are explicitly prohibited with no exceptions. Employees or Board members who breach this Policy may face disciplinary action whilst any third parties such as customers, service providers or business partners who breach this Policy may have their contract terminated with immediate effect.

Facilitation Payments and Kickback:
Making facilitation payments is illegal in many jurisdictions, and the Company does not make or accept such payments. In certain exceptional cases, a one-off exemption may be granted for facilitation payments made under coercion but strict compliance with the internal reporting procedures must be followed.

Gifts, Invitations and Hospitality:
The Policy does not prohibit normal and appropriate gifts. However, employees shall not give or offer a gift to, or accept a gift from, anyone with whom the Company does business where the gift would exceed customary courtesies associated with accepted practices in the industry. Conflict of interest, whether actual or perceived, shall be avoided and handled in accordance with the Company’s policies.
Gifts and invitations listed below are strictly prohibited:

• It is made with the intention to gain a business advantage, or to reward the provision or retention of business or a business advantage;

• It is given in the name of the Employee, Board member or Agent instead of the name of the Company;

• It includes cash or cash equivalent;

• It is of an inappropriate type and value and given at an inappropriate time; and

• It is given secretly.

In addition to the above, in general gifts to be received or gifted, shall not at any time exceed US$100.GiftsexceedingUS$100 shall be handled in accordance with the internal approval and reporting procedures.
For any other circumstances, such as where the recipient is unable to return the gifts, invitations and/or hospitality, or that the Employee would like to provide a gift to a business partner, strict compliance with the internal approval and reporting procedures must be followed.

Donations and Contributions:
The Company, its Employees, Board members and/or Agents may make donations for charitable or philanthropic causes, subject to certain conditions and approval processes. Contributions to associations are also subject to internal approval and reporting procedures. Please note that the Company is not affiliated to any political parties, nor does it intend to conduct any supporting or promotional activities in relation to any political parties and hence it shall not make contributions to any political parties.

Raising Concerns and Investigations:
Any suspicion or belief of the occurrence or solicitation of bribery or corruption or any breach of this Policy must be reported to the Chief Compliance Officer through email or direct phone. An investigation will be followed in accordance with the internal investigation procedures. To ensure effective implementation of the Policy, the Company undertakes that whistleblowers and employees who refuse to take part in bribery or corruption will be protected from detrimental treatment or retaliation.

Regulatory Reporting:
The Company commits to reporting any unlawful conduct in breach of anti-bribery and corruption rules to the Dubai Virtual Assets Regulatory Authority (VARA).

Governance:
The Board has overall responsibility for ensuring the compliance of this Policy with applicable laws and regulations.
The Compliance Officer is responsible for implementing the Policy and monitoring its effectiveness.
Management at all levels shall ensure those reporting to them acknowledge and understand this Policy and receive regular trainings.

Information and Training:
To ensure the effective implementation of the Policy, the Company provides training on the Policy's requirements and relevant laws and regulations to all Employees and Board members on an annual and ad-hoc basis.

Monitoring and Review:
The Company monitors the compliance with the Policy and regularly reviews its effectiveness. Additionally, the internal control systems and procedures are subject to regular audits.