Anti Bribery and Corruption (ABC) Policy for SFX

Sora Financial Technologies Inc. United States 1111B S Governors Ave STE 26538 Dover, DE 19904 Reg:20244413314

Turkiye Turkiye, Samsun, YENIMAHALLE MAH. 3142 SK. SHT. ASB. ÖMER HALISDEMIR APT. NO: 3 IÇ KAPI Tax ID: 4651507062

Last Updated: 10 February, 2025

Introduction

SFX is committed to conducting business with the highest ethical standards and in full compliance with all applicable laws and regulations, including Turkish anti-bribery and corruption laws. This policy outlines our dedication to preventing bribery and corruption, integrated with our Anti-Money Laundering (AML) policies to maintain a comprehensive compliance framework.

Policy Statement

2.1. Zero Tolerance: SFX maintains a zero-tolerance stance against bribery, corruption, and money laundering. We prohibit all forms of bribery, whether direct or indirect, and are dedicated to upholding integrity and transparency in all our operations.

2.2. Applicability: This policy applies to all employees, officers, directors, agents, contractors, suppliers, business partners, and any individual acting on behalf of SFX. Compliance with this policy is mandatory.

Prevention of Bribery and Corruption

3.1. Gifts and Hospitality: Employees are prohibited from offering, giving, or receiving gifts, hospitality, or any other item of value that could improperly influence a business decision. Any transactions involving funds for bribery or corruption also constitute breaches of our AML and ABC policies.

3.2. Third-Party Risk: SFX assesses and manages the risks associated with bribery, corruption, and money laundering by third parties, such as agents, intermediaries, and partners. Comprehensive due diligence is conducted to ensure adherence to our ethical standards and AML policies.

3.3. Conflict of Interest: Employees must disclose any situation where personal interests conflict with those of SFX. Such disclosures are closely monitored to mitigate the risks associated with bribery or corruption.

3.4. Facilitation Payments: SFX strictly prohibits facilitation payments, which are small payments made to expedite routine governmental actions. Employees encountering such situations must promptly report them to their supervisor and the AML compliance officer.

AML and ABC Compliance Program

4.1. Compliance Structure: SFX’s compliance program is overseen by the Chief Financial Compliance Officer (CFCO), Chief Security Officer (CSO), and CEO, ensuring alignment between AML and ABC compliance efforts.

4.2. Training: Mandatory training on AML and ABC policies is provided to all employees, agents, contractors, and relevant third parties during onboarding and regularly thereafter to maintain awareness of compliance requirements.

Regular Policy Reviews and Enhancements

5.1. Risk Assessments: AML and ABC policies undergo regular reviews based on updated bribery, corruption, and money laundering risk assessments.

5.2. Monitoring Controls: Controls over payments to third parties, hospitality, and expenses are continuously monitored to detect policy breaches, prompting necessary enhancements to procedures.

5.3. Feedback Analysis: Feedback from business units, complaints, and whistleblowing reports informs assessments of AML and ABC policy compliance, identifying areas for policy strengthening or clarification.

5.4. Clarity and Testing: Staff inquiries help identify areas where AML and ABC policies lack clarity. Internal audits and testing evaluate adherence to processes.

Compliance with Turkish Laws

6.1. Turkish Compliance: SFX fully complies with Turkish anti-bribery and corruption laws, ensuring that our AML and ABC policies align with Turkish regulations.

Consequences of Violations

7.1. Disciplinary Action: Violations of this policy will result in disciplinary action, including termination of employment, contract termination, and legal proceedings, as warranted.

Whistleblowing

8.1. Whistleblowing plays a crucial role in SFX's Anti-Bribery and Corruption (ABC) framework, fostering transparency and accountability across our operations. Employees, contractors, and stakeholders are encouraged to report any suspicions or evidence of bribery or corruption promptly. Senior executives oversee the initial review of reported incidents, ensuring confidentiality and impartiality. If necessary, matters are escalated to the board of directors. In cases involving board members, the Chamber of Commerce and Industry or the Trade Registry in Samsun is informed for further investigation and appropriate action. SFX is committed to upholding the highest ethical standards and legal compliance, and whistleblowing is integral to maintaining integrity within our organization.

Review and Amendment

8.2. Policy Review: This policy is periodically reviewed and updated by SFX to maintain effectiveness and relevance. Any amendments are communicated to all relevant parties promptly.

Contact Information

9.1. Reporting Concerns: For questions, concerns, suspected violations, or to report instances of bribery, corruption, or money laundering, please contact Martins Chiwenyte Chidume at [e-mail].