Anti-Corruption Policy

Introduction

Shoutz, Inc. is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA) and other laws that prohibit improper payments to obtain a business advantage.

This document describes Shoutz’s Policy prohibiting bribery and other improper payments in the conduct of Shoutz business operations and employee responsibilities for ensuring implementation of the Policy. Questions about the Policy or its applicability to particular circumstances should be directed to Shoutz General Counsel.

Anti-Corruption Policy

Shoutz strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether they involve government officials or are wholly commercial. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and Shoutz to possible criminal prosecution, reputational harm or other serious consequences.

This Policy applies to everyone at Shoutz, including all officers, employees and agents or other intermediaries acting on Shoutz’s behalf. Each officer and employee of Shoutz has a personal responsibility and obligation to conduct Shoutz’s business activities ethically and in compliance with the law. Failure to do so may result in disciplinary action, up to and including dismissal. Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of Shoutz’s business. Shoutz has developed a comprehensive program for implementing this Policy, through appropriate guidance, training, investigation and oversight.

Shoutz General Counsel has overall responsibility for the program, supported by Shoutz CEO. Shoutz General Counsel is responsible for giving advice on the interpretation and application of this policy, supporting training and education, and responding to reported concerns.