Business Ethics and Anti-Corruption Policy

1. Purpose

McWhite Solutions S.R.L. is committed to conducting business with integrity, transparency, and in full compliance with applicable laws and regulations. This Business Ethics and Anti-Corruption Policy establishes the principles and standards that guide our employees, contractors, and partners in their professional conduct.

2. Scope

This policy applies to all employees, contractors, consultants, and representatives of McWhite Solutions S.R.L. when conducting business on behalf of the company.

3. Compliance with Anti-Corruption Laws

McWhite Solutions strictly prohibits any form of bribery, corruption, facilitation payments, or other improper advantages in business dealings.

The company complies with all applicable anti-corruption and anti-bribery laws, including but not limited to:

• Romanian anti-corruption legislation
• European Union regulations related to bribery and corruption
• Applicable international anti-bribery standards where business is conducted

Employees and representatives must not offer, promise, authorize, give, or accept any improper payment or benefit intended to influence a business decision.

4. Gifts, Hospitality, and Entertainment

Reasonable and customary business hospitality may be permitted when it:

• is of modest value
• is not intended to improperly influence a business decision
• complies with applicable laws and the recipient organization’s policies

Gifts, hospitality, or entertainment must never be offered or accepted if they could create the appearance of impropriety.

Special care must be taken when interacting with government officials or public sector representatives, where stricter rules may apply.

5. Commissions and Third-Party Payments

Any commissions, referral fees, or payments to third parties must:

• be based on legitimate services rendered
• be documented in a written agreement
• comply with applicable laws and ethical business practices

McWhite Solutions does not permit payments to intermediaries intended to secure improper business advantages.

6. Conflicts of Interest

Employees and representatives must avoid situations where personal interests could conflict with the interests of McWhite Solutions or its clients.

Any potential conflict of interest must be disclosed to company management.

7. Accurate Books and Records

All business transactions must be accurately recorded in the company’s financial and operational records. Misrepresentation, hidden payments, or undisclosed transactions are strictly prohibited.

8. Reporting Concerns

Employees, contractors, or partners who become aware of potential violations of this policy are encouraged to report the matter to company management. Reports will be reviewed promptly and handled with appropriate confidentiality.

9. Enforcement

Violations of this policy may result in disciplinary action, termination of contracts, or other appropriate measures.

McWhite Solutions expects all employees and business partners to uphold the highest standards of professional integrity.