Anti-Corruption & Anti-Bribery Policy

Varayo is committed to conducting business ethically, transparently, and in full compliance with applicable anti-corruption and anti-bribery laws. This Policy establishes standards to prevent bribery, corruption, kickbacks, and other improper practices in all business dealings.

This Policy applies to all directors, officers, and employees of Varayo, as well as contractors, consultants, temporary staff, and third parties (including agents, representatives, intermediaries, vendors, and business partners) acting for or on behalf of Varayo

Varayo maintains a zero-tolerance approach to bribery and corruption. No covered person may directly or indirectly offer, promise, authorize, give, request, agree to receive, or accept anything of value to improperly influence a decision or secure an improper advantage.

Examples of prohibited conduct include:

• Bribery in any form involving public officials or private-sector individuals.
• Kickbacks, rebates, or undisclosed commissions intended to influence a transaction.
• Facilitation payments, except where strictly necessary to protect health or safety and permitted by law.
• Using third parties to do anything prohibited by this Policy.
• Creating false, misleading, or incomplete records to conceal improper activity.

Reasonable and bona fide business gifts, meals, travel, or entertainment may be permitted only when they are (a) modest and customary; (b) not intended to influence a decision; (c) lawful and consistent with the recipient’s rules; and (d) accurately recorded. Cash or cash equivalents (including gift cards) are prohibited.

Political donations, charitable contributions, sponsorships, and community support must never be used as a substitute for bribery or to obtain an improper advantage. Such contributions must be lawful, properly documented, and approved in accordance with internal procedures.

Varayo may conduct risk-based due diligence on third parties and may require written anti-corruption commitments. Third-party agreements may include compliance certifications, audit rights, and termination provisions for violations.

All transactions must be accurately recorded in Varayo’s books and records with reasonable detail and supported by documentation. Off-the-books accounts, undisclosed funds, or mischaracterized expenses are prohibited.

Any suspected violation of this Policy or applicable law must be reported promptly to Varayo at legal@varayo.com or 888-4-VARAYO. Varayo prohibits retaliation against any person who reports concerns in good faith or cooperates in an investigation.

Varayo will review and investigate credible reports. Violations may result in disciplinary action up to and including termination, termination of third-party relationships, and referral to law enforcement where appropriate.

This Policy may be updated periodically to reflect changes in law, risk, and business operations. Questions about interpretation or application should be directed to legal@varayo.com.