Anti-Corruption Policy

1. Introduction

Ucropit Corporation (together with its affiliated and related companies, “Ucropit”) reaffirms its commitment to integrity, transparency, and ethics in all its operations. The fight against bribery and corruption is a fundamental pillar of our corporate culture, and this policy sets out the guidelines and obligations to prevent any corrupt practices.

2. Scope of Application

This policy applies to all Ucropit employees, collaborators, clients, and suppliers. All involved parties must comply with this policy and with the regulations, policies, and procedures established by Ucropit.

3. General Principles

• Integrity and Transparency: Acting with honesty and clarity in all operations and business relationships.
• Prohibition of Bribery and Corruption: It is expressly prohibited to offer, authorize, promise, or accept any payment, gift, contribution, or benefit that could be interpreted as a bribe or act of corruption.
• Personal Responsibility: All employees are responsible for knowing and complying with this policy and for reporting any suspected irregularities.

4. Training and Awareness

Ucropit will implement documented training programs for all employees on anti-bribery and anti-corruption measures. These programs are designed to ensure that all employees understand the regulations and how to apply them in their daily work.

5. Contractual Clauses in Agreements with Clients and Suppliers

All contracts and commercial agreements signed with clients and suppliers must include a specific clause establishing the commitment of both parties to fight bribery and corruption. Ucropit reserves the right to terminate any agreement in the event of a breach of this clause.

6. Sanctions and Disciplinary Measures

Failure to comply with this policy, whether by omission or commission, will be subject to disciplinary sanctions that may include warnings, suspension, or termination of the employment or contractual relationship. In addition, legal actions may be initiated in accordance with applicable regulations.

7. Review and Update

This policy will be reviewed and updated periodically to ensure its adequacy to legislative and regulatory changes and to international best practices in anti-corruption.

8. General Provisions

• Consultation and Advice: In case of doubts or ambiguous situations, employees should seek advice from their supervisor or contact the legal department at hello@ucrop.it.
• Internal and External Disclosure: The anti-corruption policy will be published on the Ucropit Corporation website and will be available to all interested parties.
• Ethical Commitment: Adherence to this policy is an ethical commitment that is an integral part of Ucropit Corporation’s corporate culture.