Owner: General Counsel and CFO
Effective Date: 2026-06-14
Reviewed: Annually
Collection surface: Vanta (signed certification); signed-PDF mirror in SharePoint > Compliance > ABAC Certifications (
Retention: 7 years from disposition
Effective Date: 2026-06-14
Reviewed: Annually
Collection surface: Vanta (signed certification); signed-PDF mirror in SharePoint > Compliance > ABAC Certifications (
compliance.abac/certifications/<year>/) Retention: 7 years from disposition
Completed annually by staff in higher-risk roles — sales (especially international and public-sector), business development, finance/AP, procurement, executives, and anyone interacting with government officials — and at onboarding for new joiners in those roles. Assigned through Vanta. See the Anti-Bribery & Corruption Policy → Training & certification.
Certification
I, {{worker_name}}, in my capacity as {{worker_role}}, certify the following for the period {{period_start}} through {{period_end}}:- I have read and understand the policy. I have read the current Anti-Bribery & Corruption Policy, I understand my obligations under the FCPA, the U.K. Bribery Act, and other applicable anti-corruption laws, and I agree to continue to comply with it.
- No bribery. I have not, directly or through any third party, offered, promised, given, solicited, or accepted any bribe, kickback, or other improper payment or advantage to obtain or retain business or any improper advantage.
- No facilitation payments. I have not made any facilitation or “grease” payment.
- Gifts and hospitality. Any gifts, hospitality, travel, or entertainment I gave or received were bona fide, modest, infrequent, and transparent, within the limits set in the policy, and — where required — pre-approved and recorded in the Gifts & Hospitality Register. I gave no gift or hospitality to a customer or prospect during an active procurement, RFP, contract negotiation, or renewal.
- Government officials. I have not given anything of value to a government official without the prior written approval of the General Counsel as required by the policy.
- Books and records. All transactions I authorized or recorded are accurately and fairly reflected in Neuroscale’s books and records; I have not created or participated in any false, misleading, or incomplete record, and I have not maintained any undisclosed or off-book account or fund.
- Third parties and red flags. I escalated to the General Counsel any red flags I observed (e.g., requests for cash or third-country payments, refusal to certify compliance, unusual commission structures, vague invoices, or relationships with government officials).
- Conflicts and disclosures. Except as described below, I am not aware of any conduct by me that would constitute a violation of the policy, and I have reported any suspected violations by others through an approved channel. (Describe any exceptions, or state “None”: {{exceptions}})
Signature
Signature: _______________________________ Printed Name: {{worker_name}} Title: {{worker_role}} Date: ___________________________________Variables
| Variable | Description |
|---|---|
{{worker_name}} | Certifier’s full legal name |
{{worker_role}} | Certifier’s title or role |
{{period_start}} | Start of the certification period (YYYY-MM-DD) |
{{period_end}} | End of the certification period (YYYY-MM-DD) |
{{exceptions}} | Description of any exceptions or disclosures, or “None” |
Cross-references
- Anti-Bribery & Corruption Policy — full policy, gifts/hospitality limits, training & certification.
- Gifts & Hospitality Register — disclosure log for gifts and hospitality.
- Whistleblower Policy — reporting channels and anti-retaliation protections.
- Records Retention Schedule — 7-year retention of FCPA-relevant records.
Version history
| Version | Date | Description | Author | Approved by |
|---|---|---|---|---|
| 1.0 | June 14, 2026 | Initial version | Cameron Wolfe | Ishan Jadhwani |