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Anti-Corruption Policy

Purpose & Objective

This policy outlines the principles that Zenviba Ventureprises Inc. and its affiliates (collectively "Zenviba" or "we") follow to achieve zero-tolerance against bribery and corruption. The objective of our anti-corruption policy is to ensure that appropriate anti-corruption and bribery procedures are in place across the globe to avoid any violations of relevant laws and regulations, including, among others, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act 2010.

Scope

This policy applies to all officers, directors, shareholders, employees and appointed third party representatives of Zenviba (including but not limited to agents, intermediaries, consultants and introducers) in all locations. Violation of this policy will be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of employment and possible referral to the appropriate criminal and/or regulatory authorities.

Zenviba intends to review doing business with others who do not commit to the same standard of zero-tolerance of corruption, including joint ventures partners and distributors.

Policy Requirements

Zenviba has embedded within its business the following principles and controls to achieve zero tolerance against bribery and corruption:

     1. No Acceptance or Offering of Bribes and Facilitating Payments

Strictly prohibited from giving or receiving bribes (i.e. personal benefit for any improper advantage) as well as facilitating payments (regardless of whether these are common practices in a particular country) which involve anything of value to government officials in order to expedite or facilitate routine, non-discretionary government actions.

     2. Charitable and Political Donations

Prohibited from payment of donations that are linked to obtaining any improper advantage, including facilitating payments.

     3. Gifts and Entertainment

Prohibited from providing gift or entertainment to clients, prospects, government officials or their family members when such expenses are not incurred while conducting company business and/or do not satisfy this policy and our related policies.

     4. Payments and Recordkeeping

All relevant expenditures must be properly documented, approved and maintained for a minimum of 6 years.

     5. Government Officials

Required to adhere to our additional recordkeeping requirements regarding all expenditures related to government officials. Written prior approval is required when a certain threshold is exceeded.

     6. Due Diligence on Third Party Representatives

Required to conduct an appropriate due diligence review on background, reputation, and business capability before engaging or contracting with any third-party representatives and to include anti-corruption provisions in any such contract.

     7. Periodic Training

Required to carry out appropriate training to employees regarding the Anti-Corruption Policy and their role to ensure compliance.

Monitoring & Reporting

We shall monitor compliance with our Anti-Corruption Policy. Further, all persons covered by this policy must promptly report any violation or suspected violation of this policy to the General Counsel or the Director of Compliance.