Anti-Bribery & Anti-Corruption Policy

1. Our Commitment

Osapher (ABN 18 459 403 998) operates a compliance infrastructure platform. We hold ourselves to the highest standards of ethical conduct. We have a zero-tolerance policy for bribery, corruption, and facilitation payments in any form — whether involving public officials, private individuals, or third parties acting on our behalf.

2. Legal Framework

This policy reflects our obligations under:

• The Criminal Code Act 1995 (Cth) — Division 141 (bribery of Commonwealth public officials)
• The Corporations Act 2001 (Cth) — provisions relating to improper use of position
• The Crimes Act 1961 (NZ) — sections relating to corruption and bribery
• Applicable state and territory legislation in Australia

3. Prohibited Conduct

The following conduct is strictly prohibited for all Osapher personnel, contractors, and agents:

• Offering, promising, giving, requesting, or accepting a bribe or corrupt payment
• Making facilitation payments to expedite routine government actions
• Using a third party as a conduit for payments that would themselves be prohibited
• Falsifying records or accounts to conceal prohibited conduct
• Retaliating against anyone who reports a concern in good faith

4. Gifts and Hospitality

Reasonable, proportionate, and transparent gifts and hospitality in a business context are not prohibited. Any gift or hospitality that could reasonably be perceived as intended to influence a business decision must be declined and reported to legal@osapher.com.

5. Reporting Concerns

Anyone who becomes aware of actual or suspected bribery, corruption, or other unethical conduct involving Osapher personnel or operations is encouraged to report it promptly. Reports may be made to:

• Email: legal@osapher.com
• Security disclosures: security@osapher.com

Reports made in good faith will be treated confidentially and will not result in retaliation against the reporting person. Osapher will assess all credible reports promptly and, where appropriate, refer the matter to relevant authorities.

6. Consequences

Violations of this policy may result in termination of employment or engagement, referral to relevant law enforcement authorities, and civil or criminal liability for the individual involved.

7. Review

This policy is reviewed annually or when material changes in applicable law or our business operations require it.

8. Contact

Policy enquiries: legal@osapher.com

Osapher · ABN 18 459 403 998 · Melbourne, Victoria, Australia