ANTI-BRIBERY POLICY

SC Rapid Link SRL applies a zero-tolerance principle toward bribery in any form. We work with public institutions, private companies, and international partners. Their trust is founded on the fact that every contract is awarded and executed exclusively on the basis of quality, price, and technical competence.

We comply with the anti-corruption legislation of the Republic of Moldova, including the Criminal Code and Integrity Law No. 82/2017. We also comply with applicable laws in all jurisdictions where we operate. Company management personally commits to this policy and allocates the necessary resources for the proper functioning of the anti-bribery management system, implemented and certified in accordance with the ISO 37001 standard.

This policy applies to:

• the administrator, executive management, and all employees, regardless of position or type of employment;
• business partners acting on behalf of or in the interest of the company: subcontractors, suppliers, consultants, agents, intermediaries, and partners in joint ventures or consortia.

It is strictly forbidden, directly or through intermediaries:

• to offer, promise, give, solicit, or accept any undue advantage (money, gifts, services, employment opportunities, favors) to influence a decision or reward inappropriate conduct;
• to make facilitation payments to expedite routine administrative procedures;
• to promise, offer, or accept advantages in exchange for exerting influence over decision-makers (trading in influence);
• to conceal transactions or record them inaccurately in accounting records.

These prohibitions apply equally to dealings with public officials and private sector representatives.

A significant portion of our business is conducted through public procurement; therefore, we adhere to strict additional rules:

• we communicate with contracting authorities exclusively through the official channels stipulated by the procurement procedure;
• we do not solicit or use confidential information regarding the procedure, evaluation, or competitors' bids;
• we do not engage in anti-competitive agreements, such as bid rigging, market allocation, or cover bidding;
• we disclose any conflict of interest and withdraw from proceedings where it cannot be properly mitigated;
• we challenge decisions exclusively through legal channels, namely before the National Agency for Dispute Settlement (ANSC) or in court.

Gifts and hospitality are acceptable only if they are reasonable, occasional, transparent, and cannot be perceived as influencing a business decision. The following are strictly prohibited:

• gifts in cash or cash equivalents, such as gift vouchers and cards;
• any advantage offered to individuals involved in an ongoing procurement process.

Gifts received or offered exceeding the nominal value established by internal procedures must be declared and recorded in a dedicated register.

Rapid Link does not make political contributions on behalf of the company. Donations and sponsorships are granted transparently, with management approval, and only after thorough due diligence on the beneficiary. They must never be linked to obtaining a contract or favorable decision.

Before entering into an engagement, we assess the bribery risk associated with the partner (due diligence), proportionate to the nature of the relationship. Contracts with partners include anti-corruption clauses, and any breach thereof results in contract termination. Remuneration of partners must strictly correspond to services actually rendered.

To prevent bribery, we enforce comprehensive financial and non-financial controls:

• segregation of duties;
• multi-level payment approval (at least two approval levels);
• prohibition of unjustified cash payments;
• complete and accurate accounting records;
• periodic reviews of high-risk processes: tendering, procurement, and contract execution.

The anti-bribery compliance function has the following responsibilities:

• oversees the implementation of the policy;
• provides guidance and counsel to employees;
• examines and investigates received reports and alerts.

We encourage everyone—employees, partners, clients, or third parties—to report any attempt, suspicion, or breach of this policy. Reports should be made in good faith or based on reasonable belief.

• Email: sesizari@rapidlink.md
• Phone: +373 69833670
• In writing: SC Rapid Link SRL, 71/7 Gh. Asachi St., Chisinau, marked "Confidential – Anti-Bribery Compliance"

Reports may also be submitted anonymously, and the reporter's identity remains strictly confidential. No person will suffer retaliation, discrimination, or disciplinary action for reporting in good faith. The same protection applies to anyone who refuses to participate in bribery, even if such refusal results in a loss of business opportunity.

For employees, violation of this policy constitutes a serious disciplinary offense and may result in immediate termination of employment. For business partners, non-compliance results in contract termination. Conduct constituting a criminal offense will be promptly referred to law enforcement authorities.

Employees receive periodic anti-corruption training. The anti-bribery management system is:

• internally audited;
• reviewed annually by executive management;
• evaluated by an accredited independent certification body.

This policy serves as a framework for establishing and reviewing anti-bribery objectives. It is reviewed periodically and whenever significant legislative or operational changes occur.