& Corruption.

Webrandz Media Group, Stathon Technologies, and their subsidiaries prohibit bribery and corruption in every form — offered, received, promised, authorised, or solicited — in any jurisdiction, by any employee, contractor, agent, or representative acting on our behalf.

This policy aligns with the Irish Criminal Justice (Corruption Offences) Act 2018, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, and the OECD Anti-Bribery Convention. Where jurisdictions differ, we apply the strictest standard.

This policy applies to every director, employee, contractor, intern, consultant, and third party engaged by or representing Webrandz Media Group, Stathon Technologies, or any of their subsidiaries — including any of its operating brands: Stathon Technologies, Webrandz Health, and Webrandz Media.

It governs conduct toward public officials, private sector counterparts, intermediaries, and anyone in a position to influence a business decision affecting the company or its clients.

The following are strictly prohibited:

• Offering, promising, giving, or authorising any financial or other advantage to a public official or private party to obtain, retain, or direct business improperly.
• Requesting, agreeing to receive, or accepting any financial or other advantage intended to influence a business decision.
• Making, offering, or authorising facilitation payments — small unofficial payments to expedite routine administrative action — in any jurisdiction.
• Using intermediaries, agents, consultants, or joint venture partners to perform conduct that would be prohibited if performed directly by us.
• Funding political parties, political campaigns, or charitable causes as a substitute for, or cover for, any of the above.

Business gifts and hospitality are permitted only where they are modest, reasonable, proportionate to the business relationship, documented, and made openly — never in cash, never conditional on a decision, and never in connection with an ongoing or imminent tender, audit, or regulatory matter.

• Modest threshold: individual gifts or hospitality items with a value above €100 require prior written approval from the Founder or relevant Chief Executive.
• Cumulative threshold: total gifts or hospitality to or from any single counterpart exceeding €250 per calendar year require prior approval and are recorded in the gift register.
• Public officials: any gift or hospitality extended to a public official, regardless of value, requires prior written approval and is recorded.
• Always prohibited: cash or cash-equivalent, lavish entertainment, travel not directly related to a legitimate business meeting, or any item designed to obligate the recipient.

Charitable donations are made only to registered charities, recorded in the books, and never as a substitute for an improper payment. Political donations by the company are prohibited. Personal political activity of individuals is their private matter and is not undertaken in the name of the company.

Sponsorships — of events, publications, or initiatives — are subject to the same scrutiny as gifts and hospitality. A sponsorship tied to a specific commercial decision or regulatory relationship is not permitted.

Third parties acting on our behalf — agents, sub-contractors, referral partners, joint-venture counterparts — are subject to proportionate due diligence before engagement. Contracts include explicit anti-bribery clauses, audit rights, and termination rights in the event of breach.

Higher-risk jurisdictions and higher-risk sectors trigger enhanced due diligence, including review by the Founder before any commitment is made.

All transactions are recorded accurately, completely, and in a timely manner. No off-book accounts, false invoices, or misleading entries are permitted. Expense claims are reviewed against supporting documentation and this policy.

Internal controls are reviewed periodically against this policy, and any weakness or breach is escalated to the Founder immediately.

Any employee, contractor, client, or third party who suspects a breach of this policy — or is asked to engage in conduct that may breach it — must raise the concern through the Whistleblowing channel. Concerns are handled confidentially.

Retaliation against a person who raises a concern in good faith is itself a breach of this policy and is treated as a serious disciplinary matter.

Breach of this policy results in disciplinary action up to and including termination of employment or contractor engagement, reversal of any transaction obtained in breach, referral to competent regulatory or criminal authorities, and — where appropriate — civil recovery.

No client relationship, commercial opportunity, or personal relationship exempts any person from the obligations in this policy.