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Anti-corruption Policy

1. Purpose

The purpose of this anti-corruption policy is to establish SOGA’s commitment to conducting business ethically and transparently. We strictly prohibit all forms of bribery, corruption, and unethical conduct to ensure compliance with applicable laws and promote trust among our users, partners, and employees.

2. Scope

This policy applies to all employees, contractors, agents, partners, and third-party representatives of SogSoog (collectively referred to as „persons“). It covers all activities performed on behalf of the company, regardless of location.

3. Definition of Corruption

Corruption involves the abuse of power for personal or business gain. This includes, but is not limited to:

Bribery: offering, giving, receiving, or soliciting anything of value to influence a decision.
Facilitation Payments: Unofficial payments made to expedite routine government actions.
Kickbacks: Payments for favorable treatment in a business arrangement.
Conflict of Interest: Any situation where personal interests interfere with professional responsibilities.

4. Prohibited Conduct

SogSoog strictly forbids the following practices:

Offering, giving, or accepting bribes, gifts, or hospitality intended to influence business decisions.
Making facilitation payments, except where legally permissible and transparently reported.
Engaging in money laundering or other fraudulent activities.
Failing to disclose actual or potential conflicts of interest.

5. Responsibilities

Management:

Responsible for promoting a culture of integrity and ensuring compliance with this policy.

Employees and Representatives:

Required to comply with this policy and report any suspected violations.

6. Due Diligence and Risk Assessment

SOGSOOG conducts regular due diligence on potential partners, vendors, and suppliers. We evaluate corruption risks associated with business relationships and transactions to ensure compliance with anti-corruption laws.

7. Reporting Violations

Any individual who becomes aware of potential violations must report them immediately to their supervisor, the compliance officer, or through the confidential reporting hotline at support@sogsoog.com. Reports will be handled confidentially and without fear of retaliation.

8. Investigation and Disciplinary Action

All reported violations will be investigated thoroughly. If violations are confirmed, appropriate disciplinary action will be taken, including termination of contracts or employment, legal proceedings, and notification to relevant authorities.

9. Training and Awareness

SogSoog provides regular anti-corruption training to all employees and stakeholders to ensure they understand their responsibilities under this policy.

10. Compliance Monitoring and Review

We conduct periodic audits and reviews of our anti-corruption practices to ensure the policy’s effectiveness. Updates to the policy will be communicated promptly.

11. Legal Framework

This policy complies with international anti-corruption standards, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and applicable local anti-corruption laws.

12. Policy Amendments

SogSoog reserves the right to amend or update this policy as needed to adapt to changes in legal or business environments.

Contact for Questions or Concerns.

For questions, guidance, or further clarification, please contact our Compliance Officer at support@sogsoog.com
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By adhering to this anti-corruption policy, SogSoog demonstrates its commitment to integrity, transparency, and ethical business practices in all its operations.