Atomate is committed to conducting all business with integrity and in compliance with applicable laws. This policy sets out our zero-tolerance approach to bribery and corruption and applies to all employees, contractors, agents, and any third parties acting on Atomate's behalf.

1. Legal Framework

This policy is grounded in the UK Bribery Act 2010, which prohibits offering, promising, giving, requesting, or accepting a bribe — whether directly or through a third party — in any country. Atomate also complies with applicable anti-corruption laws in Moldova and any other jurisdiction in which it operates.

2. Prohibited Conduct

The following are strictly prohibited under this policy:

• Offering, promising, or giving any financial or other advantage to a public official or private individual to obtain or retain business, or to gain any improper advantage.
• Requesting, accepting, or agreeing to receive a bribe from any person.
• Making facilitation payments — small payments made to expedite routine government actions — regardless of whether they are customary in a particular country or context.
• Authorising or instructing another person to engage in any of the above on Atomate's behalf.

3. Gifts and Hospitality

Modest, transparent, and proportionate gifts and hospitality may be offered or accepted where they are consistent with reasonable business practice, do not create an expectation of a favour in return, and would not embarrass Atomate if disclosed publicly. Cash gifts are never acceptable. Any material gift or hospitality received or offered must be recorded and reported to management.

4. Third Parties

Atomate expects all third parties acting on its behalf — including agents, consultants, subcontractors, and joint venture partners — to comply with the principles set out in this policy. We conduct proportionate due diligence on third parties where there is a risk of bribery or corruption.

5. Record-Keeping

All financial transactions, gifts, and hospitality are recorded accurately and transparently. Records are maintained in a manner that allows for audit and review by authorised parties.

6. Reporting Concerns

Any employee, contractor, or third party who has concerns about possible bribery or corruption — whether involving Atomate staff or any party dealing with Atomate — is encouraged to raise those concerns promptly. Reports should be made to the Administrator of Atomate. Atomate does not tolerate retaliation against anyone who raises a concern in good faith.

7. Consequences of Breach

Any breach of this policy will be treated seriously and may result in disciplinary action up to and including dismissal for employees, or termination of contract for third parties. Breaches may also be reported to relevant law enforcement authorities.

8. Review

This policy will be reviewed at minimum every two years, or sooner if there are significant changes to applicable law or Atomate's operations. Overall responsibility for this policy rests with the Administrator of Atomate Limited.

Contact

Questions about this policy may be directed to info@atomate.net.