1. Purpose

Vivian Lab Ltd. is committed to conducting all of its business with integrity, transparency, and in full compliance with applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act, and relevant EU and local regulations.

The purpose of this policy is to set out our responsibilities and the responsibilities of those working with or on behalf of Vivian Lab in observing and upholding our zero-tolerance position toward bribery and corruption.

2. Scope

This policy applies to:

• All directors, officers, and employees of Vivian Lab Ltd.;
• Contractors, consultants, partners, distributors, agents, and any third parties representing or acting on behalf of Vivian Lab;
• All countries and territories where we conduct business.

3. Policy Statement

Vivian Lab strictly prohibits:

• Offering, promising, giving, requesting, or accepting any bribe or improper advantage in any form, directly or indirectly;
• Facilitating payments (small unofficial payments to secure or expedite routine actions);
• Any form of corruption, extortion, or fraud in connection with our business activities.

All business decisions must be made fairly, objectively, and in the best interests of Vivian Lab and our partners.

4. Gifts and Hospitality

Reasonable, infrequent, and proportionate gifts or hospitality intended to build legitimate business relationships may be acceptable only if they: