ANTI-CORRUPTION POLICY

TABLE OF CONTENTS

• 1.- Introduction
• 2.- Objective
• 3.- Prohibited Gifts
• 4.- Permissible Gifts
• 5.- Travel and Hospitality:
• 6.- Supplier Expenses
• 7.- Monitoring and Control
• 8.- Disciplinary Sanctions
• 9.- Validity

1.- Introduction

What is corruption?

Corruption is the willingness to act dishonestly or fraudulently in exchange for personal gain or, in this case, business gain.

Corruption is a term that generally indicates the misuse by a public official of their authority and the rights entrusted to them, as well as the authority related to it, opportunities, and connections to obtain a benefit, contrary to the law and moral principles.

At BITCOINFORME S.L and DEVTEAM S.L we are aware of the existence of these practices both in the public administration sector and in commercial relations with clients, suppliers, or business partners. Therefore, we condemn and reject corruption in all its forms and regardless of whether it occurs in the public or private sector.

Therefore, corruption is carried out through a person in a position of power who is illegally paid to make a decision that favors the payer.

The consequences of corruption are as follows:

• Corruption increases the cost of doing business.

• It creates unfair competition, harms innovation, and undermines social structures.

• It delays, distorts, and diverts economic growth and deepens poverty.
  

2.- Objective

From BITCOINFORME S.L and DEVTEAM S.L., (Bit2Me, hereinafter) this anti-corruption protocol is created in accordance with the company's code of ethics to record the will to do the right thing against any type of corruption in the relationships of Bit2me with the Public Administration or entities in the public or private sector.

3.- Prohibited Gifts

• No gift, regardless of its value, may be given or accepted as an incentive or in exchange for favorable treatment.

• Cash gifts, as well as loans, gift cards, coupons, or their equivalent are also prohibited.

• In particular, no gift will be accepted from a supplier who is involved in a selection process to provide services to Bit2Me.

4.- Permissible Gifts

• Small gifts to officials intended for use in connection with their professional duties are acceptable as long as they are within reasonable limits based on their value and context.

Gifts to officials must be previously approved by the Criminal Compliance Committee.

This Criminal Compliance Committee will approve the corresponding Procedure, which will include, among others, the following permitted gifts:

• Institutional mementos to visiting Officials or Authorities at Bit2me, such as commemorative plaques or photographs of the event.

• Acknowledgements for specific actions.

• Gifts (mugs, t-shirts, sweatshirts, etc.) to speakers at professional events organized by Bit2me.

• Gifts of small value for the Christmas Holidays.

• Clients or suppliers who are not Officials: any gift under €50, in relation to matters related to Bit2Me's activity, is acceptable as long as it is within reasonable limits based on its value and context and is not given for the purpose of obtaining an inappropriate advantage or agreement. It is understood that this type of gift corresponds to acknowledgments for the provision of services that are not expressly remunerated, as they are not expressly contracted or agreed upon.

5.- Travel and Hospitality:

Travel and hospitality for officials and authorities:

The Criminal Compliance Committee may invite officials, authorities, and persons close to the company or with common/commercial interests to attend professional events that it organizes or sponsors.

This hospitality is acceptable to the extent that it is within reasonable limits based on its value and context.

Bit2Me may include the payment of travel and accommodation expenses, provided that it is included in the corresponding Procedure approved by the Criminal Compliance Committee with a specific price and tourist class category.

When the general rule does not apply, Employees must obtain prior authorization from the Criminal Compliance Committee before paying travel and accommodation expenses for a Public Official.

Travel tickets, whether for plane or train, will be tourist class fares, and accommodation will preferably be in four and five-star hotels (not luxury) and in standard rooms. Any exception to this general criterion must have the approval of the Criminal Compliance Committee.

→ When paid for by Bit2Me, all aspects of the trip will have a legitimate professional purpose, and excursions or recreational activities in general will not be permitted.

→ Likewise, Bit2Me will not cover the expenses of entertainment activities nor will it allow the attendance of companions.

Other persons who are not Officials:

The Board of Directors may sponsor the attendance of clients who are not Officials at technical events organized by third parties of recognized solvency, or at events of a scientific, professional, educational, or promotional nature organized or sponsored by the company.

Common requirements:

Additionally, any sponsored travel or hospitality (whether for officials or clients) must be provided exclusively in strict compliance with the following guidelines and restrictions:

• All travel plans and expenses must have been approved by the Criminal Compliance Committee.

6.- Supplier Expenses

Following Bit2Me's supplier contracting protocol, the organization must negotiate the following expenses with suppliers (where applicable, with the authorization of the Criminal Compliance Committee):

→Payment for flights and hotels or payment to the travel agency selected to organize the travel arrangements.

If it is decided that the company will pay these expenses, the Board of Directors will directly pay all travel expenses for the guests and will in no case provide money to the guests or allow the guests to organize their own travel arrangements.

→ To ensure transparency, Bit2Me may send an email with the invitation to the external company, entity, or administrative body to which the guests belong, indicating the planned itinerary and detailing which expenses the company itself will cover.

→ All expenses, such as travel and accommodation, as well as meals, will be reasonable in terms of cost, taking into account the circumstances and applicable custom and practice.

→All expenses must be accurately and detailedly recorded and will be justified with the pertinent invoice or receipt.

7.- Monitoring and Control

→ Communication Channel

All members of the Criminal Compliance Committee have the duty to report illicit behavior, irregularities, and non-compliance of which they are aware to the Board of Directors - after the corresponding investigation in accordance with the criminal disciplinary regime protocol.

Such communications will be treated with the utmost confidentiality and will not cause any harm to the employee who, acting in good faith, has reported any circumstance that, in their opinion, could contravene the provisions of the law and/or this Protocol.

These communications, in addition to serving to uncover possible irregularities, are an essential tool for the Anti-Corruption Protocol to be fully effective and to continuously improve our prevention system.

Daily activity can reveal ethical conflicts and dilemmas in which the application of the provisions of this Protocol is not always easy. These doubts should be raised with the Criminal Compliance Committee, through the reporting channels established for this purpose.

8.- Disciplinary Sanctions

Failure to comply with any of the rules and principles contained in this Protocol will be analyzed in accordance with the internal procedures called the disciplinary regime and other applicable criminal regulations.

When a breach is identified by the Criminal Compliance Committee or the

Board of Directors, the People Department will determine the application of disciplinary measures according to the system of offenses and sanctions set out in the applicable collective agreement or in labor legislation.

9.- Validity

This Protocol will be subject to periodic reviews and updates that will depend, among other things, on the evolution of the sector and experience.