Anti-Corruption Policy

Safeera prohibits bribery, kickbacks and corrupt influence in every form. This Policy applies to Safeera directors, officers, employees, contractors and agents. Suppliers, installers, brokers and other partners must meet corresponding obligations when required by their agreements. No commercial target or instruction overrides this Policy or applicable law.

1. Prohibited benefits

Do not offer, promise, authorize, give, request or accept anything of value to improperly influence a decision, secure an improper advantage or reward a breach of duty. The rule applies to public and private recipients and to indirect benefits through relatives, charities, consultants or intermediaries.

Benefits include cash, gifts, meals, travel, entertainment, discounts, equipment loans, free GPU time, inference credits, employment, investment opportunities and charitable support. A small amount is not automatically permissible. A benefit may be improper even if the intended result never occurs or the recipient refuses it.

2. Officials, permits and utilities

Government-related decisions include permits, inspections, public procurement, customs, taxes, grants and utility or public-institution decisions. A state-owned enterprise employee, public hospital representative or person acting for an authority may require official-related review.

Do not make facilitation payments to accelerate routine action. Pay legitimate fees only through an authorized channel against an official schedule, invoice or receipt. Do not use an expediter to do indirectly what Safeera cannot do directly. Resolve uncertainty before payment with the responsible company decision-maker and qualified legal advice where needed.

3. Gifts, hospitality and contributions

Before providing a business benefit on Safeera’s behalf, obtain recorded approval from the CEO or a designated authorized reviewer. The reviewer must consider purpose, value, recipient, timing, applicable rules and any pending commercial or official decision. Government-linked benefits, political contributions, charitable support connected with a decision and third-party paid travel require advance legal review as well as business approval.

The CEO must not approve a transaction involving the CEO’s own conflict. Such a matter requires review by a disinterested authorized director or an independent qualified adviser acting under appropriate company authority. Approval cannot legalize a prohibited payment.

Employees and representatives must disclose offered benefits that could influence their work and decline improper benefits. Cash, cash equivalents and concealed personal payments are prohibited. Reasonable legitimate hospitality must be transparent, accurately recorded and consistent with applicable recipient rules.

4. Intermediaries and procurement

Before engaging a sales agent, sourcing broker, installer, permit intermediary or consultant, assess identity, ownership, qualifications, relationships, work scope and compensation. Contracts must describe genuine services and prohibit improper payments. Payments must match documented work and the identified lawful recipient.

Escalate demands for cash, unexplained commissions, unrelated offshore accounts, secrecy, fictitious invoices, payments to relatives or a refusal to identify beneficial owners. Do not proceed with an unresolved warning sign merely because a GPU shipment, permit or customer contract is time-sensitive.

5. Books, records and authority

Record transactions completely and accurately, including business purpose, recipient, value, approvals and supporting evidence. Do not create off-book accounts, split transactions to avoid approval or label a payment falsely. Agents and automation may prepare records, but a responsible human must approve a consequential payment or exception.

Retain records for the applicable legal and contractual period and preserve material under a legal hold. No one may alter a record to conceal a concern or obstruct an investigation.

6. Immediate threats and reporting

Protect life and physical safety in an immediate threat. A payment made under genuine duress involving imminent physical harm must be reported as soon as safely possible and accurately recorded; this is not permission for a commercial convenience payment.

Report suspected misconduct promptly to legal@safeera.ai with “Confidential conduct report” in the subject, or use the Safeera Speak-Up and Non-Retaliation Policy. Do not investigate by accessing information unlawfully. Protected reports to authorities or counsel may be made without company permission.

7. Enforcement and governance

Good-faith reports and cooperation must not lead to retaliation. Safeera will assess concerns, address conflicts in the review process and take proportionate corrective action, which may include stopping a transaction, discipline, ending an engagement or making a legally required report.

The CEO is accountable for implementing this Policy and arranging appropriate review as the business changes. Anyone acting for Safeera must understand the requirements relevant to their role. No waiver permits conduct prohibited by law. Postal contact: Safeera, Attention: Legal, 101 Jefferson Dr., Menlo Park, CA 94025, United States.