PhotoRobot Anti-Corruption Policy

This document represents the PhotoRobot Anti-Corruption Policy: Version 1.0 — PhotoRobot Edition (uni-Robot Ltd., Czech Republic).

uni-Robot Ltd. (operating under the brand PhotoRobot)
Vodičkova 710/31
110 00 Prague 1
Czech Republic

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1. Purpose of Policy

This Anti-Corruption Policy defines PhotoRobot's commitment to conducting business ethically and without corruption in any form.

PhotoRobot maintains a zero-tolerance policy toward bribery, corruption, facilitation payments, and unethical influence.

This policy applies to all employees, management, contractors, and representatives acting on behalf of PhotoRobot.

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2. Prohibition of Bribery

PhotoRobot strictly prohibits:

• Offering, promising, or giving any undue advantage to obtain business or influence decisions
• Accepting bribes or improper advantages
• Indirect bribery through intermediaries
• Facilitation payments of any kind

This prohibition applies in both public and private sector interactions.

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3. Gifts, Hospitality & Business Courtesies

Reasonable business hospitality may be permitted if it:

• Is transparent and proportionate
• Has legitimate business purpose
• Does not influence or appear to influence decision-making
• Complies with applicable laws

Excessive, inappropriate, or secret gifts and benefits are prohibited.

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4. Conflicts of Interest

Employees and representatives must avoid situations where personal interests conflict with company interests.

Potential conflicts must be disclosed to management immediately.

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5. Third Parties & Intermediaries

PhotoRobot may engage distributors, partners, or service providers.

The company expects all third parties to:

• Comply with anti-corruption laws
• Act with integrity
• Avoid unethical practices

Engagements with third parties must be based on legitimate business justification.

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6. Record Keeping & Transparency

PhotoRobot maintains accurate and transparent financial records.

No off-the-books accounts or hidden transactions are permitted.

All payments must be properly documented and authorized.

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7. Reporting & Protection Against Retaliation

Suspected violations of this policy may be reported to:

legal@photorobot.com

Reports will be handled confidentially.

Retaliation against individuals who report concerns in good faith is strictly prohibited.

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8. Compliance & Enforcement

Violations of this policy may result in:

• Disciplinary action
• Termination of contracts
• Legal action where applicable

Management is responsible for oversight and enforcement of this policy.

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9. Review and Updates

This Anti-Corruption Policy is reviewed periodically and updated as necessary to reflect legal or organizational changes.

The current version is available via the PhotoRobot Trust Center.