Anti-Corruption Statement

PM tec, Inc. Anti-Corruption and Business Ethics Policy

Purpose

PM tec, Inc. is committed to conducting business with the highest standards of integrity, transparency, and compliance. This policy establishes guidelines on anti-corruption, business ethics, payment of commissions, and the provision of gifts or entertainment to customers or government officials.

Scope

This policy applies to all PM tec employees, contractors, consultants, and third-party representatives acting on behalf of the Company, regardless of location.

Anti-Corruption and Anti-Bribery

PM tec strictly prohibits bribery, kickbacks, facilitation payments, or any improper advantage offered or received, whether directly or through intermediaries. Compliance with all applicable anti-corruption laws is mandatory. ‘Anything of value’ includes cash, gifts, entertainment, travel, charitable donations, or employment favors.

Gifts, Meals and Entertainment

Modest, reasonable gifts or entertainment may be offered only when:
• They serve a legitimate business purpose.
• They are not lavish or excessive.
• They do not create an appearance of impropriety.

Special restrictions apply when dealing with government officials:
• Gifts, entertainment, or travel for government officials require prior written approval and must comply with legal and contractual obligations.

Commissions and Third-Party Payments

All commissions, referral fees, or payments to third parties must be:
• Transparent, documented, and approved in accordance with PM tec’s internal controls.
• Never used as a means to influence decisions or gain improper advantage.

Engagement with Government Officials

No gifts, entertainment, or payments may be offered to government officials without prior compliance review and approval. Facilitation payments—small payments intended to expedite routine government actions—are strictly prohibited.

Reporting and Enforcement

Employees must report any suspected violations immediately through:
• Their manager
• Human Resources
• PM tec’s Compliance Officer
• Or the confidential reporting channel
PM tec enforces a zero-retaliation policy for good-faith reporting.

Training and Accountability

All employees must complete annual compliance training. Violations of this policy may result in disciplinary action, up to, and including, termination.

Statement of Commitment

PM tec, Inc. is dedicated to ethical business practices and full compliance with anti-corruption laws. Every employee and partner is expected to uphold these principles in all interactions with customers, suppliers, and government officials.