Anti-Bribery & Anti-Corruption.

Last updated: August 16, 2026

1. Our commitment

empowered.guru, LLC conducts business ethically and in compliance with the U.S. Foreign Corrupt Practices Act (the "FCPA"), the U.K. Bribery Act 2010, and equivalent anti-corruption laws in any country where we operate. We do not pay, offer, promise, authorize, solicit, or accept bribes or anything of value intended to influence an official act or business decision improperly.

2. Who and what this applies to

This policy applies to every employee, contractor, and authorized agent of the Company, and to every third party acting on our behalf (consultants, brokers, referral partners, joint-venture partners, suppliers that interact with customers or officials on our behalf). It applies anywhere in the world, and to both giving and receiving bribes. Local law does not authorize a violation of U.S. or U.K. law.

3. Key definitions

• "Anything of value" means any benefit, including cash, gifts, hospitality, travel, favors, offers of employment, charitable or political donations made at the direction of a third party, or anything else that a reasonable person would consider valuable.
• "Foreign official" includes any officer or employee of a non-U.S. government, any non-U.S. political party or official, any candidate for non-U.S. political office, any officer or employee of a non-U.S. state-owned or state-controlled enterprise, any officer or employee of a public international organization, and any person acting on behalf of any of the above.
• "U.S. official" includes any U.S. federal, state, or local officer or employee, any U.S. political candidate or party, and any officer or employee of a U.S. public international organization.
• "Improper purpose" means influencing an official act or business decision, inducing the recipient to violate a duty, securing an improper advantage, or rewarding improper performance.

4. The rules

You may not, directly or indirectly, in connection with the Company's business:

1. Offer, promise, give, or authorize the giving of anything of value to any person to obtain or retain business or an improper advantage.
2. Offer, promise, give, or authorize the giving of anything of value to any foreign official or U.S. official to influence an official act or decision, induce a violation of a lawful duty, secure an improper advantage, or influence the retention of business.
3. Request, accept, or agree to accept anything of value in exchange for an improper act or decision.
4. Make a facilitation payment. A facilitation payment is a small payment to a foreign official to expedite a routine, non-discretionary governmental action the official is already bound to perform. The Company prohibits facilitation payments even where local law permits them. If you are pressured for one, refuse, document the demand, and report it to compliance.
5. Use a third party to do any of the above. The Company is responsible for the acts of its third parties acting on its behalf.
6. Retain any undisclosed off-the-books funds or assets.

5. Government and foreign officials

Interactions with government officials require heightened care. You must obtain pre-approval from compliance before:

• Offering or paying for any hospitality for a foreign official or U.S. official, including meals, travel, lodging, or event attendance.
• Making a charitable or political donation on behalf of the Company, or at the direction of a foreign official or U.S. official.
• Hiring or engaging a current or former foreign official or U.S. official, or a family member of one, as an employee, contractor, or consultant.
• Submitting a bid, proposal, or response to a government solicitation.

6. Gifts, hospitality, and travel

The Company allows normal, appropriate business gifts and hospitality that are:

• Not cash or cash-equivalent (no gift cards, crypto, or loans).
• Reasonable in value (under US$250 per recipient per year for non-officials; lower thresholds apply for officials and require pre-approval).
• Infrequent.
• Lawful under the recipient's own rules and the recipient's employer's policies.
• Not given in exchange for an act or decision, and not capable of being reasonably perceived that way.
• Recorded accurately in the Company's books and records.

Gifts and hospitality to or from a foreign official or U.S. official always require pre-approval from compliance, regardless of value.

7. Third parties and intermediaries

Before engaging a third party that will interact with customers or officials on the Company's behalf, we:

• Conduct due diligence appropriate to the risk (beneficial-ownership check, sanctions screening, adverse-media review, references, and a written certification of compliance).
• Document the engagement in a written contract that includes audit rights, termination for cause, and representations about compliance with FCPA, the UK Bribery Act, and equivalent laws.
• Provide the third party with a copy of this policy.
• Monitor the engagement on an ongoing basis, proportionate to the risk.

A red flag is any one of: a request for cash payment, a request for payment to a third country, an unusually high commission, a lack of qualifications, a recommendation from an official, or a refusal to commit to anti-bribery terms. Any red flag is escalated to compliance before the engagement proceeds.

8. Books and records

We keep books, records, and accounts that, in reasonable detail, accurately and fairly reflect all transactions and dispositions of assets. No undisclosed or off-the-books funds or assets may be established or maintained for any purpose. Expense reports and invoices must be supported by source documentation and submitted on time. Any "slush fund," fictitious invoice, or mischaracterization is a violation regardless of size.

9. Training and certification

Employees and contractors in client-facing, sales, finance, and leadership roles receive anti-bribery training on hire and annually. Training covers this policy, the FCPA, the UK Bribery Act, gifts-and-hospitality limits, and how to raise a concern. Completion is tracked and recorded.

10. Reporting and investigation

Report any actual or suspected violation to compliance@empowered.guru or via our confidential channel (encrypted email or, where local law allows, a third-party hotline). Reports can be made anonymously. Retaliation against anyone who reports in good faith is a violation of this policy and grounds for discipline up to termination.

11. Discipline

A violation of this policy is grounds for discipline up to and including termination of employment or engagement, and may result in personal civil and criminal liability for the individuals involved. The Company cooperates fully with law enforcement.

12. Contact

Compliance: compliance@empowered.guru. Legal: legal@empowered.guru.

See also our Export Control and Responsible AI policies.