Effective date: August 19, 2026
Policy owner: Chief Executive Officer
Locunity Inc. (“Locunity,” “we,” “us,” or “our”) is committed to conducting business honestly, ethically, and in compliance with applicable law.
Locunity prohibits all forms of bribery and corruption in both the public and private sectors. We do not tolerate bribery, kickbacks, extortion, facilitation payments, or other improper payments or benefits, whether made directly or through another person or organization.
This policy applies to all Locunity directors, officers, employees, contractors, consultants, agents, representatives, and other third parties acting for or on behalf of Locunity.
Everyone covered by this policy must comply with it in every country where Locunity conducts business, regardless of whether a particular practice may be locally customary.
No person covered by this policy may directly or indirectly:
These prohibitions apply to dealings with government officials and with private-sector individuals and organizations.
“Anything of value” includes money, cash equivalents, gifts, meals, entertainment, travel, lodging, employment or internship opportunities, discounts, favors, services, confidential information, political contributions, charitable donations, sponsorships, and any other benefit.
A government official may include:
Interactions involving government officials require particular care. No payment, gift, hospitality, travel, or other benefit may be provided to a government official unless it is lawful, modest, for a legitimate purpose, accurately documented, and approved in advance by Locunity’s Chief Executive Officer or an authorized designee. It must never be intended to influence an official act or obtain an improper advantage.
Locunity prohibits facilitation or “grease” payments intended to secure or expedite routine government action, even where such payments may be customary.
Locunity also prohibits kickbacks, secret commissions, and payments made in response to commercial extortion.
If a person makes a payment because of an immediate and credible threat to personal health or safety, the person must prioritize safety and report the incident to Locunity as soon as reasonably possible. The payment must be recorded fully and accurately. This safety exception does not permit payments made merely to obtain or expedite routine governmental or commercial action.
Business courtesies must be lawful, modest, infrequent, transparent, and connected to a legitimate business purpose. They must never create—or reasonably appear to create—an obligation or improper influence.
Locunity personnel and representatives must not:
Unless a stricter limit applies, a business courtesy may not exceed US$150 per recipient per item or occasion without advance written approval. A customer’s, partner’s, or recipient’s lower limit or prohibition always controls.
Locunity funds, assets, or resources may not be used for political contributions without formal written authorization from appropriate company management and confirmation that the contribution is lawful.
Political contributions, charitable donations, community investments, and sponsorships may never be offered or used to influence a decision improperly, obtain business, or secure an unfair advantage. All such transactions must have a legitimate purpose and be documented accurately.
Locunity may be responsible for improper conduct undertaken by agents, consultants, contractors, suppliers, intermediaries, or other third parties acting on its behalf.
Locunity therefore uses reasonable, risk-based care when selecting and overseeing third parties. Third-party compensation must be reasonable, supported by legitimate services, properly documented, and paid through appropriate channels.
Red flags—including requests for cash, payments to unrelated accounts or countries, vague services, unusually high commissions, false invoices, or refusal to follow this policy—must be investigated before proceeding.
All Locunity transactions must be recorded completely, accurately, and in reasonable detail. Locunity prohibits:
Supporting documentation must accurately describe the purpose, recipient, amount, and nature of each transaction.
Anyone who knows of or reasonably suspects bribery, corruption, or another violation of this policy must report it promptly.
Reports may be submitted to: Locunity Inc., Attn: Compliance, 2261 Market Street, STE. 68363, San Francisco, CA 94114. Email: Support@Locunity.com
Reports will be handled as confidentially as reasonably practicable. Locunity prohibits retaliation against anyone who makes a good-faith report, asks a compliance question, or participates in an investigation.
Where an incident may affect a customer, partner, or other organization and Locunity has a contractual or legal reporting obligation, Locunity will make the required notification promptly.
Locunity communicates this policy to relevant personnel and third parties and provides training appropriate to their responsibilities and level of risk.
Everyone covered by this policy must cooperate with compliance reviews and investigations. Violations may result in disciplinary action, termination of employment or engagement, cancellation of a business relationship, recovery of losses, or referral to appropriate authorities.
When applicable laws, contractual requirements, or recipient policies impose a stricter standard than this policy, the stricter standard applies.
Questions about this policy or a proposed transaction should be raised before taking action by contacting Support@Locunity.com.
Locunity will review and update this policy periodically to reflect changes in its operations, legal obligations, and responsible business practices.
© 2026 Locunity Inc. All rights reserved. Locunity and “Where Community Happens” are trademarks or service marks of Locunity Inc.