Legal

Anti-Bribery, Corruption, and Financial Crime (ABC & AML) Policy

Last updated: November 9, 2026

1. Purpose and Scope

Eloquent AI is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all business dealings. This policy concerns Eloquent AI’s own business activities. Customers remain responsible for their own anti-money laundering programmes, regulatory decisions, and reporting obligations. Any support Eloquent AI provides is limited to the services expressly agreed in the applicable customer agreement. Eloquent AI remains responsible for its own obligations under applicable law and that agreement.

This policy sets out our zero-tolerance approach to bribery, corruption, money laundering, tax evasion, and any other form of financial crime. It applies to:

Eloquent AI, Inc. (United States)

All directors, officers, employees, contractors, consultants, and suppliers acting on behalf of the company anywhere in the world.

2. Definitions

Bribery: Offering, giving, receiving, or soliciting something of value to influence an action or decision improperly.

Corruption: Abuse of entrusted power for private gain.

Money Laundering: Concealing or disguising the origins of funds obtained from illegal activity.

Facilitation Payments: Unofficial or small payments made to secure or expedite routine actions, these are prohibited.

Criminal Finance Offence: Failure to prevent the facilitation of tax evasion under the UK Criminal Finances Act 2017.

This policy is informed by the following laws and frameworks, to the extent applicable to Eloquent AI’s business activities:

  • UK Bribery Act 2010
  • UK Criminal Finances Act 2017
  • US Foreign Corrupt Practices Act (FCPA)
  • US Bank Secrecy Act and Anti-Money Laundering laws
  • Applicable EU and international anti-corruption conventions

4. Policy Statement

Eloquent AI prohibits all forms of bribery, corruption, money laundering, and facilitation of tax evasion. We will:

  • Conduct business transparently, fairly, and in compliance with law.
  • Reject improper gifts, payments, or inducements.
  • Ensure accurate and complete financial record-keeping.
  • Maintain risk-based controls to detect and prevent financial crime in Eloquent AI’s own business activities.
  • Require equivalent standards from all business partners and third parties.

5. Responsibilities

Leadership and Management: The leadership team is responsible for promoting a culture of integrity and ensuring that adequate controls, reporting mechanisms, and reviews are in place.

Employees and Contractors: Everyone working for or with Eloquent AI must:

  • Avoid any activity that might lead to, or suggest, bribery or corruption.
  • Report immediately any suspicion of financial crime or unethical conduct.
    Complete any required compliance or due-diligence checks before engaging with clients, vendors, or intermediaries.

Suppliers and Partners: Suppliers must maintain ethical standards, comply with all applicable anti-bribery and AML laws, and cooperate with Eloquent AI’s due-diligence processes.

6. Gifts, Hospitality, and Entertainment

Gifts and hospitality may only be offered or accepted if they:

  • Are reasonable, proportionate, and infrequent;
  • Are given openly and transparently; and
  • Cannot be perceived as an attempt to influence a business decision.

Cash or cash equivalents (e.g. gift cards) must never be offered or accepted. Any gifts or hospitality that might exceed local norms must be disclosed to the designated compliance contact for approval.

7. Preventing Money Laundering and Tax Evasion

Eloquent AI will not engage in or facilitate money laundering, terrorist financing, or tax evasion. To mitigate risk, the company will:

  • Conduct reasonable checks on clients, suppliers, and partners.
  • Conduct risk-based checks on Eloquent AI’s own business payments and receipts for unusual or suspicious activity.
  • Escalate any suspicion of money laundering or criminal finance to the designated compliance contact immediately.

Employees are prohibited from concealing, transferring, or converting funds known or suspected to be derived from criminal activity.

8. Record-Keeping and Controls

Eloquent AI maintains accurate financial records consistent with its accounting and audit controls. All payments, invoices, and expenses must be properly authorised and supported by appropriate documentation. Falsifying records or making off-book payments is strictly prohibited.

9. Reporting Concerns

Employees and partners must report any suspected breach of this policy to the designated compliance contact or via established internal channels. Internal and external parties may report concerns to privacy@eloquentai.co. Reports will be handled confidentially to the extent reasonably practicable and permitted by law. Eloquent AI prohibits retaliation against anyone raising a concern on reasonable grounds.

Any suspension or termination of Customer Services remains subject to the Terms of Service and applicable law.

10. Training and Awareness

Eloquent AI will provide periodic training and awareness materials to ensure employees understand how to recognise and prevent bribery, corruption, and financial crime in their roles.

11. Continuous Improvement

This policy will be reviewed annually and updated as required to reflect evolving legal obligations, operational risks, or best-practice standards.

/s/ Tugce Bulut
Tugce Bulut, Co-Founder and CEO of Eloquent AI, Inc.
For and on behalf of Eloquent AI
Date: November 9, 2026
Last updated: November 9, 2026