Micromedia Compliance Statement

Updated 3-2025

1. Scope and Purpose

This statement describes Micromedia’s commitment to doing business ethically and in compliance with applicable laws across our operations and partnerships.

2. Anti-Bribery & Anti-Corruption (ABAC)

Micromedia maintains a zero-tolerance position on bribery and corruption and complies with applicable laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010. We prohibit offering, promising, giving, requesting, or accepting anything of value to improperly influence any act or decision, including in dealings with Government Officials. Facilitation payments are prohibited. We maintain internal controls to prevent, detect, and remediate violations.

3. Gifts, Hospitality, Conflicts of Interest & Political/Charitable Contributions

• Gifts and hospitality must be reasonable, infrequent, and not intended to obtain an improper advantage; cash or cash equivalents are prohibited.
• Any interaction with Government Officials requires heightened scrutiny and (where required) prior approval.
• Personnel must disclose and properly manage any actual or potential conflicts of interest.
• Political and charitable contributions must be lawful, transparent, and never used to influence business decisions.

4. Export Controls & Sanctions

Micromedia complies with applicable export control and economic-sanctions regimes (including, where applicable, EU, UK, U.S. EAR and OFAC rules).

• We do not transact with embargoed destinations or denied/debarred/sanctioned parties and we screen relevant parties accordingly.
• We do not support prohibited end-uses (e.g., WMD, missile/UAV proliferation, or other restricted military/intelligence end-uses).
• We may suspend or cancel orders to comply with law or upon identification of sanctions risk.

5. Anti-Money Laundering & Counter-Terrorist Financing (AML/CTF)

We comply with applicable laws, perform reasonable due diligence, keep accurate books and records, and apply controls on payment methods to mitigate financial-crime risks.

6. Human Rights, Labour Standards & Environment

Micromedia supports internationally recognized human rights and commits to:

• No child, forced, or compulsory labour; fair and safe working conditions; non-discrimination; and respect for lawful freedom of association.
• Ethical business conduct and fair trading practices.
• Environmental responsibility, including reducing environmental impact and complying with laws on hazardous substances and waste.

7. Product Environmental Compliance

Where applicable to our product set and role, Micromedia will:

• Comply with product environmental regimes (e.g., RoHS, REACH, WEEE) and provide available compliance documentation on request.

8. Data Protection & Information Security

We comply with applicable data-protection laws (including GDPR where applicable). We implement appropriate technical and organizational measures for security and confidentiality. If a personal-data breach affecting a customer occurs, we will notify the parties without undue delay in accordance with applicable law and our contractual role (controller/processor).

9. Training & Awareness

Micromedia provides periodic training appropriate to role and risk—covering ABAC, export/sanctions, AML/CTF, and data protection. New relevant personnel receive onboarding training and periodic refreshers.

10. Whistleblowing & Non-Retaliation

Micromedia maintains channels for reporting suspected misconduct in good faith (including anonymous reporting where permitted) and prohibits retaliation against anyone who raises a concern.

11. Competition/Antitrust

Micromedia complies with applicable competition/antitrust laws, including prohibitions on price-fixing, bid-rigging, market/customer allocation, and sharing competitively sensitive information outside lawful contexts.

12. Enforcement & Remedies

Micromedia may suspend performance, refuse or cancel orders, or terminate affected agreements if necessary to comply with law or in response to material breach of this Statement. These remedies are without prejudice to any other rights or remedies available at law or under contract.

13. Updates

We may update this Statement to reflect changes in law or best practice. The current version will be made available to customers upon request.