Anti-Bribery and Corruption Policy of Unbound XR

1. Purpose and scope

Unbound XR is committed to conducting its business with with integrity, honesty and transparency. This Anti-Bribery and Corruption Policy sets out the standards and procedures that all employees, officials, directors, agents and representatives of Unbound XR must follow to prevent any form of bribery and corruption in the course of business. The policy applies to all business activities and transactions worldwide.

2. Definities 

For the purposes of this policy, the following definitions apply:

a. Bribery: Offering, giving, receiving or soliciting any form of value to influence, directly or indirectly, the actions or decisions of an individual in a position of trust.

b. Corruption: The abuse of entrusted power for personal gain.

c. Associated person: Any individual person or organization performing Services for or on behalf of Unbound XR, including but not limited to agents, consultants, contractors, intermediaries, joint venture partners and distributors.

3. Compliance with laws

Unbound XR is committed to complying with all applicable laws and regulations with relating to bribery and corruption, including but not limited to the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and local laws and regulations. All employees, officers, directors, agents and representatives of Unbound XR must comply with these laws and regulations.

4. Prohibition of Bribery and Corruption

Unbound XR prohibits offering, to give, receiving or soliciting any form of bribe or other reward, direct or indirect, to or from any person or company to obtain or retain business or obtain any improper advantage. This applies to all employees, officers, directors, agents and representatives of Unbound XR, as well as associated persons.

5. Gifts, Entertainment and Hospitality

Unbound XR recognizes that giving or receiving reasonable and proportionate gifts, entertainment or hospitality is common practice in business. However, such gifts, entertainment or hospitality must not be used as a means of exerting influence or obtaining an improper advantage. All gifts, entertainment or hospitality given or received must be transparent and comply with applicable laws and regulations.

6. Due diligence

Unbound XR conducts due diligence on all affiliates to ensure they comply with this Policy and applicable laws and regulations with relating to bribery and corruption. This includes conducting risk assessments, obtaining references, and performing background checks as needed.

7. Reporting and research

All employees, officers, directors, agents and representatives of Unbound XR have a duty to report any suspected or actual bribery or corruption. Unbound XR will investigate all reports of bribery or corruption and take appropriate disciplinary and/or legal action against any employee, officer, director, agent or representative who violates this Policy.

8. Training and awareness

Unbound XR provides regular training and awareness programs to all employees, officers, directors, agents and representatives about this Policy and the risks associated with with bribery and corruption.

9. Consequences of Non-Compliance

Violation of this Policy and applicable laws and regulations with relating to bribery and corruption may result in disciplinary action, termination of employment and legal action, if appropriate.

10. Communication

This Policy is communicated to all employees, officers, directors, agents and representatives of Unbound XR and is publicly available on the Company's website. Questions or concerns about this policy should be directed to the Chief Compliance Officer.

This policy is effective immediately and supersedes all previous policies with regarding bribery and corruption.