Skip to main content

pH7 Technologies Anti-Bribery/ Anti-Corruption Policy

Prepared by: pH7 Technologies Compliance Officer 

The following anti-corruption Policy (“Policy”) was adopted by pH7 Technologies effective January 1, 2023


pH7 Technologies, including its affiliates and its subsidiaries (collectively, the “Company”), value honesty, transparency, integrity, and professionalism in dealings with suppliers, competitors, clients, contractors, government officials, and all other parties pH7 Technologies is involved in business dealings with. 

The scope of this Policy and Procedure applies to every pH7 Technologies’ employee, including senior executive and financial officers, and members of our Board of Directors, and reflects the standard to which the company expects it business associates, partners, agents, contractors, and consultants to adhere when acting on the company’s behalf. 

This document gives specific details on pH7 Technologies’ Policy, prohibiting corruption in the performance of its business operations and individual employee responsibilities for ensuring adherence to the Policy. 

The goal is to inform team members of their anti-corruption obligations and to ensure compliance with this policy. It also provides information on how to identify potential risks, deal with challenging situations, and report when those situations violate or may lead to a violation of this Policy.

Questions about the Policy or its applicability to specific circumstances should be directed to

Massood Moradkhan, [email protected] as the compliance officer of pH7 Technologies.


The Company’s Policy is to engage in business practices in full compliance with (the Foreign Corrupt Practices Act of 1977 (FCPA) in the United States, the Corruption of Foreign Public Officials Act (CFPOA) and the Criminal Code in Canada, or the Anti-Bribery Act, 2010 in the United Kingdom and the Ani Corruption Legislation in the European Union) together with all other anti-corruption and anti-bribery laws and regulations applicable to the Company’s business anywhere in the world (“Anti-Corruption Laws”).

Ph7 Technologies has zero tolerance for any corruption in business activities. Bribes of any form or other improper or unauthorized payments that directly or indirectly make, offer, or promise to make, kickbacks, benefits, or advantages to any person, individual, organization, or entity, are prohibited by this Policy. A violation of this Policy can occur even if a bribe or other corrupt practice fails to achieve the desired outcome.


It is the responsibility of the Executive leadership Team and the designated officer to ensure the following Procedure is adhered to. The Executive Team shall review this Policy on an annual basis for appropriateness, compliance internally with the company and for compliance with all applicable standards, acts, legislation, etc.

Requests for additional guidance or interpretation regarding this Policy can be directed to the Executive Team or designated officer.

It is the responsibility of all Senior Management, Department Managers and Team Leaders/Supervisors to ensure the functionality and accuracy of this Procedure is adhered to.

It is the responsibility of every employee to ensure the functionality and accuracy of this Procedure is adhered to. It is the responsibility of the Executive Team and the designated officer to ensure that a risk assessment and due diligence are conducted prior to the appointment of a third-party intermediary.


Corruption: Corruption is the abuse of entrusted power for private economic gain. This Policy will refer to both as “bribery.”

Bribery: Bribery is the giving, offering, or agreeing to provide benefits to others in order to improperly influence an outcome to obtain or retain an advantage. Bribery can take many forms, including the provision or acceptance of:

  • cash payments
  • phony jobs, shell companies, or “consulting” relationships
  • kickbacks
  • political or charitable contributions
  • social benefits, or
  • gifts, travel, hospitality, and reimbursement of expenses

Company employees are strictly prohibited from offering, paying, promising, or authorizing, directly or indirectly, any financial or other advantage or benefit to foreign officials, candidates or parties for the improper performance (whether it be an act, omission, use of influence or otherwise) of a relevant function or activity.

Regarding gifts since they are commonly offered as gestures of gratitude or tokens of appreciation, but in some situations, they can also be construed as bribes. pH7 Technologies does allow gifts made in good faith, but they must comply with this Policy.

Personnel must ensure that any of the items mentioned above including gifts, which are of value in proportion to the situation at hand, should be infrequent to avoid being perceived as an attempt to influence an act or a decision. When offering or accepting a gift, Personnel should specifically consider the following:

The intended outcome: Gifts can have many purposes, such as expressing appreciation and building a relationship, but they can also be viewed as an attempt to influence a direct result, e.g., to win a bid or affect the negotiation process. 

The Company’s reputation: The gift may be a private act, but if it were to come to the public’s attention, Personnel should consider how it would affect the reputation of the Company. 

Competition: A general rule of thumb is to think about how the Company would perceive a similar gift made by a competitor.

Disciplinary Action

If Personnel should fail to comply with this Policy or Anti-Corruption Laws, they will be subject to disciplinary action up to and including termination of employment or other relationship with the Company. Restitution could also be required, and civil or criminal action against individual Personnel could be warranted. 

If Personnel is involved in or aware of a situation they believe may violate or lead to a violation of this Policy, they must ask for guidance from their manager or other personnel in a superior position.


pH7 Technologies Employee_______________

Authorized Signature __________ Signature_______________

Date:____________ Date:__________________