Anti-Bribery and Corruption Policy

1. Policy Statement

AOTRACELL ENTERPRISE is committed to conducting all business operations with transparency, integrity, and strict adherence to anti-bribery and anti-corruption laws. AOTRACELL ENTERPRISE operates under a strict zero-tolerance policy toward bribery, corruption, extortion, and kickbacks.

This policy applies to all business activities, dealings, and interactions with clients, vendors, government officials, collaborators and business partners.

2. Prohibited Conduct

A. Bribery and Kickbacks

AOTRACELL ENTERPRISE will not offer, promise, give, request, accept, or receive cash, gifts, favors, or anything of value to improperly influence a business decision or secure an unfair advantage.

B. Facilitation Payments

Facilitation or “grease” payments—unofficial payments made to speed up routine government or administrative processes—are strictly prohibited.

C. Gifts and Hospitality

Gifts, meals, or business entertainment given or received in the course of business must be:

  • Modest, reasonable, and proportionate.
  • Customary for legitimate business courtesy (e.g., standard business lunches or low-value promotional materials).
  • Given openly and without expectation of preferential treatment.

3. Financial Records and Transparency

AOTRACELL ENTERPRISE maintains accurate, complete, and transparent financial books and records. All expenses, income, invoices, and payments are properly documented and accounted for. No off-the-books transactions or hidden accounts will be maintained.

4. Working with Contractors and Partners

AOTRACELL ENTERPRISE expects all subcontractors, suppliers, and business partners acting on behalf of or alongside the business to uphold equivalent standards of business ethics and anti-corruption compliance.

5. Compliance with Laws

AOTRACELL ENTERPRISE complies with all applicable national and international anti-bribery and anti-corruption laws and regulations in every jurisdiction in which business is conducted.

Date: 4 August 2026 (Ver: 2026.08)