Corporate Compliance

Effective Date: April 16, 2026 · Last Updated: April 16, 2026

AlecRae is committed to operating ethically and lawfully in every jurisdiction we serve. This page brings together our public compliance statements on modern slavery, anti-bribery, sanctions / export control and anti-money-laundering. It is updated at least annually and at any time a material change occurs.

1. Modern Slavery & Human Trafficking Statement

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act of 2010, and is provided on a voluntary basis even though AlecRae does not yet meet the statutory turnover threshold.

• AlecRae has a zero-tolerance policy to modern slavery, human trafficking, forced labour and child labour.

• Our supply chain is short and professional: cloud-infrastructure vendors, financial institutions, software libraries and professional-service firms.

• Every direct vendor engagement includes contractual representations that the vendor complies with applicable labour laws and does not use forced, bonded or child labour.

• We require vendors to have an equivalent whistleblowing channel for their own staff.

• All employees and contractors complete annual training on identifying and reporting modern-slavery concerns.

• Concerns may be reported anonymously via [email protected].

2. Anti-Bribery and Anti-Corruption

AlecRae complies with the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010 and any equivalent anti-corruption law in each jurisdiction where we do business. We:

• Prohibit offering, giving, accepting or receiving bribes or "facilitation payments" of any kind.

• Forbid political contributions on behalf of AlecRae.

• Cap gifts and hospitality to reasonable business-courtesy levels and require manager approval above a de-minimis threshold.

• Require vendors, agents and partners to adhere to equivalent anti-corruption standards.

3. Export Control, Sanctions and Restricted Parties

AlecRae is subject to US export-control laws, including the Export Administration Regulations (EAR) and the regulations administered by the Office of Foreign Assets Control (OFAC), as well as equivalent UK, EU and UN sanctions regimes.

• The AlecRae Service is not available in, or for users who are ordinarily resident in, jurisdictions subject to comprehensive US sanctions (currently: Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk and Luhansk regions of Ukraine).

• We will not knowingly contract with individuals or entities on the OFAC Specially Designated Nationals (SDN) list, the UK HMT Consolidated List, or the EU Consolidated Financial Sanctions list.

• Encryption technology in our products is classified as eligible for the Mass Market exception (ENC) under 15 CFR § 742.15(b); a BIS notification has been filed.

• Users are responsible for complying with applicable export-control laws of their own country, including re-export restrictions.

4. Anti-Money-Laundering (AML) & KYC

Although AlecRae is not itself a regulated financial institution, we operate consistently with good AML practice: we collect minimum necessary KYC data through Stripe, monitor for unusual payment patterns, and cooperate with law-enforcement requests supported by valid legal process.

5. Whistleblower Protection

Any employee, contractor, vendor or user may raise a compliance concern confidentially by emailing [email protected] or via an independent third-party hotline listed in our employee handbook. Retaliation against a good-faith reporter is a dismissable offence.