Anti-Bribery and Anti-Corruption Policy

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1. OVERVIEW

At EVOTEK, Inc. (“EVOTEK,” “we,” “our,” or “us”), we are committed to conducting our operations ethically, transparently, and in full compliance with all applicable anti-bribery and anti-corruption laws in the United States and globally. This commitment applies regardless of political or enforcement priorities and reflects EVOTEK’s expectation of full compliance in every jurisdiction.

2. SCOPE

This Anti-Bribery and Anti-Corruption Policy (“ABAC Policy”) applies to all directors, officers, employees, subsidiaries, affiliates, and any third parties acting on our behalf, including agents, consultants, distributors, lobbyists, customs brokers, channel partners, introducers, joint-venture partners, and M&A targets during diligence and integration.

3. OUR LEGAL STANDARDS

EVOTEK complies with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”), and the UK Bribery Act, where applicable. Where multiple laws apply, EVOTEK follows the highest applicable standard.

4. WHAT WE PROHIBIT

EVOTEK prohibits bribery, kickbacks, indirect bribery, facilitation payments, false or misleading accounting entries, and undisclosed or off-books accounts. We also prohibit payments to personal or shell accounts, cash payments except minimal petty cash with receipts, and require mandatory reporting of solicitation or extortion attempts by foreign officials.

5. GOVERNMENT INTERACTIONS

All interactions with government officials must be legitimate, transparent, and properly documented. Any gifts, hospitality, travel, sponsorships, or benefits involving government officials require pre-approval from Legal and must be recorded.

6. RESPONSIBLE BUSINESS PRACTICES

To prevent corruption risks, we:

• Maintain strong internal financial controls and accurate books and records;
• Conduct risk-based due diligence on third parties, including agents, distributors, and consultants;
• Include anti-corruption commitments in contracts;
• Provide regular employee training on ethical conduct; and
• Require compliance certifications where appropriate.

We expect our business partners to uphold standards consistent with our own.

7. GIFTS, HOSPITALITY & CONTRIBUTIONS

Gifts, travel, and entertainment must be modest, reasonable, lawful, and business-related. They must never be offered or accepted to influence a business decision.

Political and charitable contributions made on behalf of EVOTEK must be lawful, transparent, properly approved, and accurately recorded.

8. REPORTING

We encourage employees, partners, and stakeholders to report concerns about potential misconduct to management, Human Resources, or Legal. We strictly prohibit retaliation against anyone who raises concern in good faith.

All reports are reviewed promptly and handled as confidentially as possible.

9. ACCOUNTABILITY

Violations of our ABAC Policy may result in disciplinary action, termination of employment or contract, and referral to authorities where appropriate.

Our leadership team actively oversees our ethics and compliance program to ensure accountability at every level of the organization.