Anti-Corruption & Business Ethics Policy

Milano Software Inc. is committed to conducting all business in an honest, transparent, and ethical manner. This policy establishes standards for compliance with anti-corruption laws, ethical business practices, and responsible conduct.

This policy applies to all employees, officers, directors, contractors, consultants, and third-party representatives acting on behalf of Milano Software Inc., globally.

The Company strictly prohibits any form of bribery, kickback, facilitation payment, or improper advantage. No one may offer, authorize, solicit, or accept any payment, gift, or entertainment that could improperly influence a business relationship or government decision.

• Bribery: Offering or accepting anything of value to gain an improper advantage.
• Facilitation payments: Small, unofficial payments to secure routine actions. These are prohibited.
• Government official: Any employee or representative of a government or state-owned entity.
• Third party: Any external agent, consultant, or partner acting on behalf of the Company.

Reasonable and proportionate hospitality may be acceptable only if it is not intended to influence a business decision, and is transparent, modest, and lawful. Cash or equivalent gifts are strictly prohibited. Any expense above USD $100 must be pre-approved by management.

Commissions and referral fees must be legitimate, documented, and under valid contracts. All payments must be accurately recorded and verifiable. No unrecorded or personal payments are allowed.

Employees must conduct business fairly and honestly, avoid conflicts of interest, respect confidentiality, and report unethical behavior.

Extra caution must be applied when dealing with government entities. Nothing of value may be offered to influence official action. Legal or Compliance guidance must be sought before any government engagement.

All transactions must be properly documented, transparent, and subject to audit. False or misleading records are prohibited.

Employees must report concerns to their manager or Compliance Officer. Milano Software prohibits retaliation against good faith reports.

Violations may result in disciplinary action, termination, or legal prosecution for both individuals and the Company.

All employees must complete annual ethics training. Managers are responsible for ensuring team compliance.

This policy will be reviewed annually by Compliance and Legal to ensure its continued effectiveness.

Approved by: Chief Executive Officer — January 1, 2025