Acronis AG Global Anti-Corruption Policy

Updated September 2026

Introduction. Acronis AG, and each of its subsidiaries and other business entities controlled by it worldwide (collectively, “Acronis”), is committed to conducting business in an ethical and honest manner and to implementing and enforcing systems that ensure the prevention of bribery. Acronis has zero tolerance for bribery and corrupt activities.

Acronis’s policy is to comply worldwide with the U.S. Foreign Corrupt Practices Act of 1977, as amended (“FCPA”), and any applicable anti-bribery and anti-corruption laws and regulations of the countries in which it does business, including the UK Bribery Act of 2010 (“UK Bribery Act”) (collectively, the “Anti-Corruption Laws”).

Bribery and corruption expose organizations and individuals to significant legal, financial, and reputational risks. Acronis therefore requires all Acronis Business Partners to maintain the highest standards of integrity and ethical conduct.

This Global Anti-Corruption Policy, including any annexes, certifications, schedules, forms, amendments, updates, replacements, or successor versions published or communicated by Acronis from time to time, is referred to as the “Policy.”

Scope. This Policy applies to all “Acronis Business Partners” including:

• Channel Partners. Partners, distributors, resellers, managed service providers, service providers, agents, and other third parties engaged in the marketing, sale, distribution, implementation, or support of Acronis products and services;
• Suppliers. Vendors, contractors, consultants, advisors, law firms, service providers, and other third parties that provide products, services, or support to Acronis; and
• Sponsored Parties. Entities and individuals engaged by Acronis in connection with sponsorship, promotional, marketing, brand-awareness, or endorsement activities.

Guiding Principles. Acronis has a strict anti-bribery policy. This Policy (and various anti-corruption laws) prohibit bribes to and from Public Officials (as defined in this Policy) and to and from individuals operating in a commercial or private capacity.

This Policy is designed to provide specific guidance on how to avoid corruption risks and adhere to Acronis’s high ethical standards in circumstances that may arise in the conduct of its business.

Acronis Business Partners are expected to comply with all applicable anti-corruption, sanctions, export controls, anti-money laundering, fraud prevention, and ethical business conduct requirements relating to their activities on behalf of or involving Acronis. As a condition of doing business with Acronis, all Acronis Business Partners must read, understand, and comply with the policies referenced herein. Failure to comply with anti-corruption laws or anti-corruption obligations in contracts with Acronis may create liability for Acronis and may result in corrective action, suspension, termination of applicable agreements, or other remedies available to Acronis under contract or law.

Related Compliance Policies. This Policy forms part of Acronis's broader ethics and compliance program and should be read together with applicable Referenced Policies (as defined in Section 6 below) and any other compliance requirements or contractual obligations communicated by Acronis. In the event of a conflict between this Policy and the applicable Agreement, the Agreement shall govern. Where the Agreement is silent on a matter addressed by this Policy, the requirements of this Policy shall apply. Nothing in this Policy limits compliance with applicable law. Compliance with this Policy does not relieve any person or entity of its obligations under those policies, the applicable Agreement, or applicable law.

Referenced Policies. For purposes of this Policy, “Referenced Policies” means the Acronis policies, standards, guidelines, procedures, certifications, compliance materials, and related requirements identified in this Policy or otherwise communicated by Acronis to Acronis Business Partners from time to time, including policies relating to sanctions and export controls, anti-money laundering, ethics, data protection, privacy, information security, artificial intelligence, supplier management, market development funds, platform usage, and other compliance matters. References in this Policy to a Referenced Policy include any amendment, update, replacement, successor, consolidation, or renamed version of that policy or document addressing substantially the same subject matter.

Referenced Policies may be made available through the Acronis website, partner portal, supplier portal, compliance certification process, contractual documentation, onboarding materials, compliance communications, or other channels designated by Acronis.

Acronis Business Partners are responsible for reviewing and complying with applicable Referenced Policies relevant to their relationship with Acronis. Where this Policy, an applicable agreement, certification, onboarding requirement, or compliance notice requires compliance with a Referenced Policy, that Referenced Policy forms part of Acronis's compliance requirements for the applicable business relationship. Failure to comply with an applicable Referenced Policy may result in corrective action, suspension, termination of applicable agreements, or other remedies available under contract or law, subject to applicable law and contractual rights.

Prohibition on Bribery and Corruption

This Policy and the Anti-Corruption Laws prohibit bribery. Bribery refers to the act of offering, giving, promising, or authorizing, or extorting, soliciting, accepting, or receiving “anything of value” to improperly influence the actions of a person to obtain or retain business, secure an improper advantage, or otherwise induce or reward improper conduct. In almost all cases, simply offering a bribe is unlawful, even if the bribe is not accepted.

Acronis’s policies and the Anti-Corruption Laws, prohibit improperly giving items of value, whether directly or indirectly, through a third party (e.g., an Acronis Business Partner), to anyone, including employees of private companies and Public Officials. Bribery and corruption can just as easily occur in the private sector as in the public sector.

Acronis Business Partners must not use agents, subcontractors, consultants, resellers, distributors, or other third parties to circumvent applicable laws, contractual obligations, or the requirements of this Policy. Acronis Business Partners must exercise appropriate oversight and must not ignore or disregard red flags suggesting that a third party may be engaging in bribery, corruption, improper payments, or other unlawful conduct relating to Acronis business.

Definition of Bribe

A bribe refers to any inducement, reward, or other “thing of value” offered to another individual to gain commercial, contractual, regulatory, or personal advantage. Bribes can take many forms and include non-monetary items. The term “thing of value” is construed broadly to include any financial or other advantage that could be used to improperly influence someone. Bribes can include items of value given to family members or other people or organizations related to or selected by the person involved. Some items that may constitute a bribe include:

• Payments of money, including small facilitation payments such as paying a customs official to expedite the clearance of goods;
• Cash equivalents (e.g., gift cards, gift certificates, or vouchers);
• Extension of credit or loans;
• Gifts, meals, and entertainment;
• Lavish business-related travel and accommodations expenses;
• Non-business travel and accommodations expenses, including expenses related to family members;
• Political contributions and charitable donations;
• Free use of Acronis services, facilities, or property;
• Inflated commissions, invoices or consultancy arrangements;
• Inappropriate discounts, rebates, or sales incentives;
• Favors that are of value to a recipient (e.g., offering a job to a member of a person’s family); and
• Anything else of value.

Facilitating and Expediting Payment

Acronis strictly prohibits the offer or payment of “facilitating,” “expediting,” or “grease” payments in connection with its business. These types of payments are small, unofficial customary payments to lower-level government functionaries whose purpose is to expedite or to secure performance of a routine, non-discretionary governmental action, which includes, but is not limited to:

• Performing ministerial actions, such as obtaining permits, licenses or other official documents to qualify a company to do business;
• Processing governmental papers such as visas and work orders;
• Providing civil services, such as police protection, mail and delivery service and scheduling inspections; or
• Providing phone service, utilities, cargo loading and unloading services and protecting perishable products from deterioration.

If the Acronis Business Partner is asked by a Public Official to make a payment like this, the Acronis Business Partner must refrain from making such payment and report the incident to Acronis [email protected].

In some situations, there may be publicized, official expediting fees paid to the government for the performance of certain services. For example, some countries publish official rates for the rush processing of a visa or passport. Payment of such publicized, transparent, government fees are permitted if the fee is paid to the applicable government entity (and not to the Public Official).

Definition of Public Official

Acronis’s policies and the Anti-Corruption Laws prohibit improper payments to anyone, including employees of private companies, who are not government employees.  However, dealing with individuals who work for, or are part of, a government entity or department or agency of a government often presents a greater risk, particularly in jurisdictions where the risk of corruption is high.  Under the FCPA, these individuals are often referred to as “foreign officials.”  In other laws, these individuals are referred to as “public officials.”  Because different laws use different terms, anyone described the following paragraphs is a “Public Official.”

This policy defines the term “Public Official” broadly to include (i) elected or appointed government officials, officers or employees; (ii) persons acting in an official or public capacity on behalf of a government; (iii) any person exercising judicial, legislative, executive, administrative, or regulatory functions for or pertaining to the government (including any independent regulator); (iv) any member of the royal or ruling family of a country; (v) any political party, party official, officer, employee or other person acting for or on behalf of a political party; (vi) candidates for political office; and (vii) any employee, officer, agent or other person acting for or on behalf of any entity that is wholly or partially owned or controlled by a government, or any public, quasi-public, or non-governmental international organization.

The term Public Official can also include such person’s family members and close contacts, and any other persons defined as such under local laws. Government instrumentalities include state-owned, state-run, and state-managed organizations and businesses (e.g., universities, hospitals, telecommunications operators, etc.), meaning that any person working on behalf of any such organizations and businesses are Public Officials. A Public Official may also include former government officials or consultants who are advising a government or any Public Officials. Keep in mind that a company may be owned or controlled by the government even if a government does not own more than 50% of that company. For example, a company could be state controlled through law or statute and the ability of the government to appoint senior management or the board of directors.

Acronis may be held responsible even if the Acronis Business Partner’s payment or conduct is prohibited by Acronis and regardless of whether Acronis had knowledge of the payment. Therefore Acronis Business Partners must comply with applicable anti-corruption laws, cooperate with reasonable compliance inquiries, and, to the extent legally permissible, promptly report any credible allegation or evidence of bribery, corruption, improper payments, or related misconduct involving Acronis’s business activities and maintain controls reasonably designed to prevent, detect, and address bribery and corruption risks in connection with Acronis’s products, services, incentives, rebates, discounts, MDF, customer engagements, and government-related opportunities.

Areas of Risk

It is important for all Acronis Business Partners to be aware of situations that may give rise to a higher risk of bribery or corruption. When such situations arise, they must be disclosed so that Acronis can take effective steps to ensure that the risks are appropriately assessed or mitigated. Situations that may give rise to a higher risk of bribery or corruption include the following:

• High value contracts in which there are increased incentives for corruption;
• Dealings with Public Officials in territories that are perceived as having a higher risk of bribery or corruption;
• Engaging with parties in territories that are perceived as having a higher risk of bribery and corruption;
• Bidding on government tenders, contracts, or engaging in a government bidding process;
• Working with customs or tax officials to get preferential treatment in customs clearances or to avoid audit related issues;
• The securing of operating licenses and permits that are required to operate in a particular territory;
• Negotiations around taxation incentives for investment in a particular territory or region; and
• Obtaining required import or export licenses.

Due Diligence, Compliance and Flow-Down Requirements

Acronis applies risk-based due diligence procedures that may include review of ownership, compliance history, government affiliations, sanctions exposure, compensation structures, and other risk factors. Acronis reserves the right to decline, suspend, restrict, or terminate a relationship where it determines, acting reasonably and in accordance with applicable law and contractual rights, that compliance risks have not been adequately addressed or that the proposed or ongoing relationship may expose Acronis to legal, regulatory, reputational, or other material risk.

Acronis Business Partners are responsible for the compliance of their employees, officers, directors, representatives, agents, consultants, subcontractors, downstream resellers, sub-distributors, and other third parties engaged in connection with Acronis-related activities. Such parties must take reasonable measures to ensure that these third parties comply with applicable anti-corruption laws and regulations and, where appropriate based on the nature of the relationship and associated risks, impose written obligations that are substantially equivalent to the anti-corruption requirements contained in this Policy and to evaluate such prospective third party in accordance with applicable Referenced Policies relating to sanctions, export controls, and third-party risk management.

Acronis Business partners are expected to cooperate with reasonable due diligence and compliance review requests and provide accurate, complete, and not misleading information. Upon reasonable request, business partners must provide information concerning relevant subcontractors, resellers, sub-distributors, agents, consultants, and other third parties engaged in connection with Acronis-related activities.

Acronis Business Partners must promptly notify Acronis, to the extent legally permissible, if they become aware of any credible allegation, government inquiry, enforcement action, bribery concern, corruption risk, or other material compliance matter involving themselves or any third party engaged in connection with Acronis-related activities.

Where applicable, agreements with Acronis Business Partners, and other downstream business partners should contain anti-corruption representations, warranties, audit rights, certification obligations, and other compliance protections substantially in the form set forth in Annex A (Form Anti-Corruption Contract Clauses). All such third parties engaged by a business partner in connection with Acronis-related activities should be subject to comparable written anti-corruption obligations appropriate to the nature and risk of the engagement.

Formal Engagement of Third Parties by Acronis Business Partners

• Written agreements should require detailed reports or invoices from the third party describing the services rendered. Cursory descriptions such as “consulting services” are not sufficient.
• All fees and expenses paid to third parties must constitute justifiable and proportionate remuneration, which is commercially reasonable under the circumstances, for legitimate services rendered by the third party.
• Payments must be made by the third party to the Acronis Business Partner and not by or to any other person or entity. Payments by or to an Acronis Business Partner in a country other than one in which the services or transactions are provided may indicate possible corruption, and requests to make such “offshore” payments should be treated as red flags, warranting further investigation.

Post-Engagement Monitoring of Third Parties

While pre-engagement due diligence is critical, it is equally important to conduct periodic risk-based monitoring of third parties on an ongoing basis. These efforts could include the following:

• Providing periodic anti-corruption compliance training wherever appropriate;
• Updating diligence periodically as a condition to renewing a third-party relationship;
• Adjusting the degree of scrutiny as market conditions change and problematic activities are detected; or
• Exercising audit rights where appropriate which are subject to the applicable agreement.

Due Diligence Documentation and Recordkeeping

Business Partners should maintain records reasonably sufficient to demonstrate risk-based due diligence conducted on relevant third parties.

Market Development Funds

Acronis provides Market Development Funds (“MDF”) to qualified Acronis Business Partners to subsidize the costs for marketing and sales initiatives and activities that drive demand for Acronis products, solutions, and services. Because the Acronis Business Partners are responsible for managing these funds, all Acronis Business Partners are obligated to ensure that these funds are not used for improper purposes and to prevent the creation of off-the-books funds.

All marketing and sales activities and initiatives are subject to a formal approval process, must be submitted through Acronis’s designated MDF process and must comply with the MDF guidelines found here: /MDF, applicable Referenced Policies governing MDF, rebates, incentives, and marketing expenditures. The MDF guidelines have been developed to ensure that all expenditures by Acronis Business Partners who are reimbursed through MDF are preapproved, adequately supported with receipts and other documentation, and that the expenses incurred are for legitimate business purposes (such as training or product demonstration) pursuant to this and other Acronis policies and are otherwise reasonable.

Acronis Business Partners are responsible for ensuring that subcontractors, marketing agencies, consultants, event organizers, and other third parties receiving MDF-supported funds comply with equivalent anti-corruption requirements.

Acronis Business Partners may be required to certify on an annual basis that they are not using MDF in a manner that violates this Policy or any other applicable Acronis policies governing expenditures for marketing activities, and that the use of MDF comports with the Anti-Corruption Laws and is otherwise reasonable.

Acronis Business Partners must maintain accurate books and records for all MDF expenditures, including any required documentation such as program descriptions, proof of performance, and proof of cost.

Discounts and Rebates

Acronis frequently discounts the price of its products and services and provides rebates and other incentives as part of the sales process. These discounts and rebates are sometimes extended to Acronis Business Partners. A significant, non-standard discount, rebate, or other incentive is a common red flag indicating possible corruption. For example, a significant, non-standard discount can be used to:

• Create a fund held by a third party for purposes other than as reflected on the transaction documents provided to the Acronis Business Partner. For example, increasing the discount or rebate on a transaction to create an undisclosed or “off the books” budget or pool to be used for marketing, travel or entertainment is prohibited;
• Fund Gifts, Travel and Entertainment or bribes;
• Compensate undisclosed third parties; or
• In any manner other than as described in any documentation requesting approval of the discount, rebate or incentive.

Acronis Business Partners are prohibited from offering or authorizing discounts, rebates, or other incentives to any downstream reseller, customer or third party if the discount, rebate, or incentive will be used in any manner outlined herein.

Acronis Business Partners must ensure that their downstream agreements concerning Acronis products and services contain contractual provisions stating that any assets or funds paid to or entrusted with them, such as non-standard discounts, rebates, MDF, or other incentives can only be used for the specific purpose authorized or intended.

Political Donations and Lobbying

Acronis Business Partners must comply with all applicable laws governing political contributions, lobbying activities, and political engagement. Acronis Business Partners may not make any political contribution, sponsorship, donation, or other payment, whether directly or indirectly, on behalf of Acronis or in a manner that could reasonably be perceived as intended to influence a government official, political candidate, political party, or political organization for the benefit of Acronis. Acronis Business Partners must not use any funds, resources, or compensation received from Acronis to make political contributions on Acronis's behalf. Political contributions and lobbying activities can be subject to significant legal restrictions and may result in civil or criminal liability if conducted improperly.

Charitable Donations

Acronis supports legitimate charitable giving and community initiatives. However, Acronis Business Partners must ensure that charitable donations, sponsorships, or similar contributions are not used as a means of obtaining business, securing an improper advantage, influencing a business decision, or otherwise engaging in bribery or corruption. Acronis Business Partners may not offer, make, or facilitate any charitable donation or sponsorship in connection with Acronis business where the purpose or effect is to improperly influence a customer, government official, or other third party. Where a charitable donation, sponsorship, or similar contribution is requested in connection with Acronis-related business activities, the Acronis Business Partner must obtain Acronis's prior written approval before making or facilitating such donation or contribution on behalf of, or for the benefit of, Acronis.

All donations are to be made transparently and never in a situation that may give rise to a feeling of obligation on the part of a business partner of Acronis or that otherwise creates the impression of an intent to improperly influence a Acronis business partner. Nothing in this Policy prohibits individuals acting solely in their personal capacity from making lawful charitable donations. However, such donations must not be represented as being made on behalf of Acronis or in connection with Acronis-related business activities.

Gifts, Travel, and Entertainment

In general, anti-corruption laws are not intended to prohibit reasonable business-related gifts, travel, or entertainment. However, gifts, travel, and entertainment also present the risk of bribery or the appearance of bribery. This is particularly true with Public Officials. In many cases, Public Officials cannot accept any gifts, travel, or entertainment no matter how small in value. Please follow the guidelines below for examples of acceptable levels of gifts, travel, and entertainment (subject to any lower limits imposed by applicable laws or customer policies) and when prior approval in advance is necessary.

Gifts

“Gifts” include anything of value, such as merchandise, goods, wine, spirits, food, vacations, trips and tickets to sporting events, concerts, shows, entertainment or similar events, which are provided free of charge or below market rate. Note that there is a distinction between the “gifting” of tickets for sporting events, etc. and business “hospitality” involving sporting events where an Acronis Business Partner representative is in attendance. Please note that a gift certificate, gift card or voucher may be viewed as giving cash.

Acronis generally discourages offering, giving and receiving gifts. Acronis-branded items that carry nominal or small value (e.g., coffee mugs, t-shirts, pens, etc.) are permissible gifts.

In certain circumstances, however, it may be appropriate to give or accept gifts consistent with local custom or as a matter of courtesy. It is important to understand that gifts can constitute bribes. Therefore, Acronis Business Partners must ensure that the offering, solicitation and receipt of gifts does not give rise to even the appearance of bribery, corruption or improper conduct.

All gifts must be:

• Permissible under local law and the Anti-Corruption Laws (both with regards to giving and receiving the gift);
• Permissible under policies of the individual or entity giving and receiving the gift. Note that the acceptance of a gift by the person receiving the gift may also be prohibited under local laws or the rules of that person’s employer;
• A reasonable and bona fide expenditure directly related to the legitimate conduct of Acronis’s business, such as promoting Acronis’s products and services, executing a contract, or cooperating on industry matters;
• Reasonable in value given the context and must not appear lavish or extravagant;
• Offered and accepted in a transparent manner and not solicited;
• Not intended to create any feeling of obligation on the part of the recipient or otherwise influence the recipient in an improper manner (any gifts offered during an ongoing tender process will not be in accordance with this principle);
• Not in cash or cash equivalents (such as gift vouchers, gift certificates, or gift cards);
• Given in the name of the Acronis Business Partner and not in the name of Acronis or any Acronis employee;
• Fully documented and supported by original receipts; and
• Accurately recorded in Acronis Business Partner’s books and records.

Acronis Business Partners must not request gifts. Where gifts are offered, they may only be accepted in accordance with Acronis’s policy. Business Partners should disclose gifts that exceed a reasonable nominal value or otherwise present a potential compliance concern upon Acronis's reasonable request.

Travel and Entertainment

“Travel and Entertainment” includes invitations to sporting, entertainment or similar events, meals, and related travel and accommodation costs. Although Travel and Entertainment for third parties and customers may be appropriate in certain contexts (e.g., for a site visit that forms an essential part of implementation of a project or to provide training in relation to a particular project), this may be a violation of the law if it is excessive, unreasonable, or lacks a valid business purpose. Acronis Business Partners must be certain that the offer and receipt of Travel and Entertainment do not give rise to even an appearance of impropriety.

All Entertainment and Travel expenses must be:

• Permissible under local law and the Anti-Corruption Laws (both regarding offering and receiving the Entertainment and Travel);
• Permissible under policies of the entity offering or receiving the Entertainment and Travel;
• Reasonable in value given the context and not appear lavish or extravagant;
• Offered and accepted in a transparent manner and not solicited;
• Not intended to create any feeling of obligation on the part of the recipient or otherwise influence the recipient in an improper manner (special consideration needs to be given to Entertainment and Travel during an ongoing tender process);
• To facilitate a genuine business meeting or demonstration of Acronis products or services;
• Fully documented and supported by original receipts; and
• Accurately recorded in Acronis Business Partner’s books and records.

The following are indications that Entertainment or Travel may not be reasonable:

• Location is not a facility using Acronis products;
• Bringing a spouse or family member;
• Side trips and unnecessary stops;
• Too many people in attendance;
• Too many locations;
• Too many visits in one year;
• First class airfare;
• Luxury hotel suites; or
• No meeting agenda or vague topics.

From time to time, Acronis invites customers and others to sporting events Acronis sponsors (e.g., Formula 1 events) where Acronis is demonstrating its products and services. This category of Travel and Entertainment is permissible under this Policy.

Acronis Business Partner may not engage in repeated acts of Gifts, Travel, and Entertainment with the same recipient such that the total benefit to the recipient is inappropriate or excessive and not use third parties to circumvent the requirements of this Policy.

Books and Records and Internal Accounting Controls

Acronis Business Partners must maintain a system of internal accounting controls and make and keep accurate books and records that fairly reflect, in reasonable detail, all transactions and dispositions of assets and are maintained in accordance with applicable accounting and auditing standards. False or misleading documentation will result in corrective action, suspension, termination of applicable agreements, or other remedies available to Acronis under contract or law. No Acronis-related funds or assets may be used for any unlawful, improper or unethical purpose. All Acronis financial books and records must be maintained in accordance with applicable accounting and auditing standards.

Supporting documentation, including original receipts, invoices or other relevant documents, for expense reimbursements must be filed with the expense reports and maintained for a reasonable period of time. Such documentation must state the following: (i) description of the expenditure; (ii) purpose for which the expenditure is made; (iii) identification of the recipient; (iv) amounts involved; and (v) manner of payment.

Training and Communication

Acronis Business Partners shall provide anti-corruption training appropriate to the size, risk profile, and nature of their business activities. When necessary, specialized training will be provided to directors, officers and/or employees with significant compliance responsibilities or in high-risk functions. Acronis’s policy and zero-tolerance attitude must be clearly communicated to all third parties with whom Acronis Business Partners do business at the outset of business relations, and as appropriate thereafter.

Annual Certification

Acronis Business Partners may be required to certify compliance with this Policy, applicable Referenced Policies, and related contractual compliance obligations communicated by Acronis.

Question, Concerns, and Reporting Requirements

Any questions about any part of this policy should be directed to Acronis.  If an Acronis Business Partner has reason to believe that a violation of this policy has occurred (or will occur), it is their duty to report it immediately to Acronis [email protected]. The report may also be made anonymously through the whistleblower hotline www.report.syntrio.com/acronis.

Non-Retaliation. Acronis strictly prohibits any discrimination, retaliation or harassment against any person who reports a concern or who participates in any investigation of a concern. Any complaint that discrimination, retaliation or harassment has occurred will be promptly and thoroughly investigated. If it is found that there was discrimination, retaliation or harassment against any Acronis Business Partner because of a reported concern or cooperation in an investigation, then appropriate action will be taken as outlined in this policy.

ANNEX A

FORM ANTI-CORRUPTION CONTRACT CLAUSES

Neither [X] nor [X]’s employees, directors, officers, agents, or subcontractors will, directly or indirectly, in connection with this Agreement or the business resulting therefrom, offer, pay, promise to pay, or authorize the giving of any monies or financial or other advantage or any other thing of value to any person: (a) for the purpose of inducing or rewarding that person or any other person to perform their role or function improperly; (b) for the purpose of influencing a Public Official in relation to any decision, act or other performance of their official role or function, including a decision to fail to perform that role or function, so as to obtain or retain business or a business advantage of any kind; or (c) that is otherwise in breach of (i) any applicable Anti-Corruption Laws or (ii) Acronis’s Anti-Corruption Policy (the “Anti-Corruption Policy”).

Neither [X] nor [X]’s employees, directors, officers, agents, or subcontractors will, directly or indirectly, in connection with this Agreement or the business resulting therefrom, request, accept, agree to receive, or authorize the acceptance of any monies or financial or other advantage from any person: (a) as an inducement or reward for the improper performance of any role or function; or (b) that is otherwise in breach of any applicable Anti-Corruption Laws or the Anti-Corruption Policy.

[X] agrees to keep full and accurate books and records of all payments made in connection with this Agreement, and to make all such books and records available to Acronis’s duly authorized representatives as deemed necessary by Acronis to verify [X]’s compliance with Anti-Corruption Laws and this Clause. Except as disclosed in writing in advance to Acronis, [X] has not, and will not, retain any Public Official as an employee, director, officer, agent, consultant, or otherwise, and no Public Official owns or has any direct, indirect, or beneficial interest in [X’s] activities.

[X] will use any assets or funds paid to or entrusted to it, such as discounts, rebates, or other incentives, including Market Development Funds (“MDF”), only for the specific purpose authorized or intended. [X] has not, and will not, use any discounts, rebates, or incentives, including MDF, in a manner that violates the Anti-Corruption Policy or Anti-Corruption Laws. At Acronis’s request, [X] will complete a certification prepared by Acronis and attesting that [X] has not committed any act prohibited by the Anti-Corruption Laws or the Anti-Corruption Policy and is not aware of any facts or circumstances suggesting that a violation of the Anti-Corruption Laws or the Anti-Corruption Policy has occurred or may have occurred. Acronis shall be entitled to audit or investigate all relevant documentation of [X] in order to verify compliance with the Anti-Corruption Laws’ requirements, with this Clause and with any Anti-Corruption Certification prepared hereunder, and [X] will cooperate fully in any such audit or investigation conducted by Acronis.

For purposes of this provision, “Anti-Corruption Laws” means the United States Foreign Corrupt Practices Act of 1977 and any applicable foreign or domestic anti-bribery and anti-corruption laws and regulations, as amended from time to time, including the United Kingdom Bribery Act of 2010 and any laws intended to implement the Organization for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Additionally, “Public Official” means any employee, director, officer, agent, representative, or any other person acting in an official capacity on behalf of (i) any government or any department, agency or instrumentality thereof; (ii) any legislative, administrative or judicial body; (iii) any public international organization; (iv) any state-owned or state-controlled commercial enterprise, as well as (v) any political party or official thereof or any candidate for political office. For purposes of this Agreement, “Public Official” also includes any immediate relative of the foregoing. Immediate relatives include any of the following relations, whether by blood or through marriage: spouse, parent, child, sibling, and grandparent/child.

[X] represents and warrants that all of the provisions contained in and arising from this Clause and any Anti-Corruption Certification completed by [X] shall remain true and accurate throughout the duration of this Agreement; [X] shall promptly notify Acronis should [X] learn or have any reason to know of any development during the term of this Agreement that in any way could make inaccurate or incomplete any provision in this Clause or an Anti-Corruption Certification. Failure by [X] to inform Acronis promptly of changes in any such provision shall constitute a material breach of this Agreement by [X] entitling Acronis to terminate this Agreement. Acronis may also suspend payments or performance or terminate this Agreement at any time and without liability if it believes, in good faith, that [X] has violated or may have violated any provision in this Clause or an Anti-Corruption Certification. Acronis shall not be liable for any claims arising from, or related to, unlawful activity, or claims alleging unlawful activity, of [X], regardless of the nature or location of such activity. [X] shall indemnify Acronis for and hold Acronis harmless against any actions, legal claims, demands, proceedings, internal or government investigations (whether formal or informal), inquiries, losses, damages, costs, expenses and other liabilities of whatever nature (including the payment of attorneys’ fees and investigative costs) incurred in relation to any breach of this Clause or any provision of an Anti-Corruption Certification, or in relation to investigating or defending any legal violations or claims arising from, or relating to, potential unlawful activity by [X].