Anti-Bribery and Anti-Corruption Policy

Last updated: October 8, 2026

1. Commitment

Azterion Technologies ("Azterion") conducts business with ethics, transparency and zero tolerance for bribery and corruption, in any form and toward any counterparty: clients, vendors, business partners and public officials. This commitment applies to the entire Azterion team and to third parties acting on its behalf.

2. Legal framework

We act in accordance with applicable Mexican law, including the General Law of Administrative Responsibilities, the Federal Criminal Code and the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI). Because we serve clients in the United States, we also observe the principles of the Foreign Corrupt Practices Act (FCPA) where applicable to our operations.

3. Prohibited conduct

  • Offering, promising, giving or authorizing any payment, gift or benefit to improperly influence a decision, obtain or retain business, or gain an improper advantage.
  • Soliciting or accepting bribes, kickbacks or improper benefits from third parties.
  • Facilitation payments ("grease payments"), regardless of amount.
  • Using third parties to carry out, indirectly, any conduct prohibited by this policy.
  • Recording transactions inaccurately or concealing the true nature of a transaction.

4. Gifts and hospitality

Only business courtesies of symbolic value and reasonable frequency are acceptable — never cash or equivalents, and never where they could create obligation or the appearance of influence. When in doubt, decline or consult before accepting.

5. Conflicts of interest

Any situation that could place a team member's personal interest against the interests of Azterion or its clients must be disclosed immediately for transparent evaluation and handling.

6. Third parties and business partners

We expect the same standard of integrity from our vendors, allies and subcontractors. A third-party relationship may be terminated for conduct contrary to this policy.

7. Reporting channel

Team members, clients, vendors and any third party may report, in good faith, suspected bribery, corruption, undisclosed conflicts of interest, misuse of resources or unusual transactions by writing to hello@azterion.com with the subject "Integrity report". Reports are handled confidentially and objectively, and no retaliation is tolerated against anyone who reports in good faith.

8. Consequences and review

Breaches of this policy result in disciplinary measures up to termination of the employment or business relationship, in addition to any applicable legal liability. This policy is reviewed at least once a year.