Global Employee Handbook

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(Universal Framework — supplement with Jurisdiction Annexes)

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Version: 1.1

Effective Date: August 2025

Owner: People & Culture (HR) + Legal/Compliance
Applies to: All employees, contractors, and interns of Mezzarion and its Associated Companies

Important: This Handbook is non-contractual. It guides conduct and explains policies but does not create an employment contract, vary your Universal Employment Agreement, or limit the Company’s right to amend policies, benefits, or procedures (subject to local law). Where local law or a Jurisdiction Annex grants more favorable terms, local terms prevail.

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1) Welcome & Purpose

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• Our Mission: Build sovereign-grade systems that create durable value for nations, partners, and people.

• Our Standard: Elite performance, elite rewards, elite integrity.

• How to use this handbook:
   

  1. Read the Global Sections (apply everywhere).

  2. Check your Jurisdiction Annex (local legal rules).

  3. Ask HR if anything is unclear: info@mezzarion.com.

  4. Report serious concerns: info@mezzarion, REF: Concerns

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2) Our Values & Culture

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• Conscious Profitability | Integrity First | Excellence & Ownership | Sovereign Mindset.

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3) Equal Opportunity, Dignity & Respect

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• Non-discrimination, anti-harassment, anti-bullying.

• Reasonable accommodation where required by law.

• Speak Up protections: no retaliation for good-faith reports.

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4) Code of Conduct & Ethics

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• Conflicts of Interest: disclose and obtain written approval.

• Gifts/Hospitality: modest, transparent; follow thresholds and approvals.

• Anti-Bribery: zero tolerance (public or private).

• Sanctions/AML: trade controls, KYC, no cash transactions.

• Political/Media: personal only; no Company endorsement without authorisation.

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5) Information Security, Privacy & Data Protection

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• Protect confidential and personal data; follow privacy principles and security hygiene.

• Acceptable use of systems; monitoring where lawful; report incidents within 24 hours.

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6) IP & Inventions

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• Company owns work product created in role or with Company resources.

• Respect third-party IP and licenses.

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7) Employment Basics

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• Probation (typically 3 months), classification, work hours, attendance and remote/hybrid eligibility.

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8) Compensation, Benefits & Perks

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• Market-competitive pay; lawful deductions only.

• Bonus/commission role-dependent.
   

• Benefits (unlocked after 12 months confirmed service):
   

  • 30 days annual leave (or higher by law);

  • Professional development allowance & conferences;

  • Travel allowance; relocation/housing (assignments); cultural stipend;

  • Family education support (senior roles);

  • Sabbatical 2–3 months after 5 years;

  • Leadership tracks (Tekembü/Bankaris when live);

  • Residency/citizenship assistance (case-by-case, lawful).

• Insurance & retirement per local law and Company plans.

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9) Leave & Holidays

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• Annual leave, sick leave, maternity/parental/adoption/family leave per law; Company top-ups where policy allows.

• Local public holidays observed.

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10) Travel & Expenses

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• Pre-approval required; safety protocols; reimburse reasonable, receipted, business-necessary costs per policy.

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11) Performance, Growth & Mobility

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• Reviews at probation end and annually; continuous feedback; internal mobility based on performance and business need.

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12) Health, Safety & Wellbeing

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• Follow HSE rules, training, PPE; report hazards/incidents immediately.

• Zero tolerance for workplace violence/threats.

• Substance policy: no impairment at work.

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13) Misconduct, Investigations & Discipline

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• Examples: dishonesty/fraud/bribery; harassment; data breaches; COI; insubordination; repeated absence/lateness; misuse of assets, etc.

• Process (adapted to local law): notice → fair hearing with representation → written outcome → right of appeal.

• Sanctions: coaching → warnings → final warning → demotion/transfer → termination (summary for gross misconduct where lawful).

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14) Grievances & Problem-Solving

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• Informal manager route → formal HR grievance → escalation panel; timely written responses; no retaliation.

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15) Company Assets & Property

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• Proper use/care; loss/theft reporting; accurate records; return all assets on request/exit.

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16) Communications & Social Media

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• Professionalism; protect confidentiality; authorised spokespeople only; personal posts should use “views my own” where relevant.

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17) Mandatory Global Policies (Authoritative Summaries)

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Full procedures live on the portal. Stricter local law or annex terms override these baselines.

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17.1) Anti-Bribery & Corruption (ABAC)

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• Zero tolerance for bribes, kickbacks, facilitation payments—public or private sector.

• Government officials: heightened restrictions; Compliance pre-approval required for any thing of value.

• Accurate books/records; no off-books accounts.

• Third-party due diligence, ABAC clauses, and monitoring required.

• Report immediately; no retaliation for good-faith reports.
   

17.2) Gifts & Hospitality

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• Allowed (modest, transparent): customary tokens, reasonable business meals with a clear business purpose.

• Prohibited: cash/cash equivalents (incl. gift cards), lavish travel, personal services, quid-pro-quo.

• Global thresholds (baseline; local law may be stricter):
   

  • Single item ≤ USD 50 (local equivalent); cumulative per counterparty/year ≤ USD 200.

  • Pre-approval + register anything above thresholds or involving officials.

• Record within 5 business days in the Gifts Register.
   

17.3) Trade Controls & Sanctions

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• Screen all counterparties (customers, vendors, agents, vessels, banks) before engagement and per transaction.

• Check embargoes, end-use, end-user; escalate red flags (dual-use/diversion/military).

• No controlled shipments/services without written Legal approval/licences.

• Keep records ≥5 years (or longer if law requires).
   

17.4) AML / KYC

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• Mandatory KYC: beneficial ownership, business purpose, source of funds where applicable.

• EDD triggers: PEPs, high-risk jurisdictions, complex structures, or value ≥ USD 50,000 (or lower local trigger).

• No cash for business transactions.

• Escalate suspicious activity to Compliance within 24 hours for STR/SAR consideration.

• Annual AML training & attestation required.
   

17.5) Privacy & Data Protection

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• Principles: lawful basis, purpose limitation, minimisation, accuracy, security, retention limits.

• Data Subject Requests → Privacy Team; respond within 30 days (or faster if required locally).

• Cross-border transfers via SCCs/approved mechanisms; DPAs with processors.

• Breach: notify Security/Privacy immediately; triage within 24 hours; external notices per law.
   

17.6) Information Security (Passwords/MFA, Classification, Incidents)

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• MFA everywhere; minimum 12-character passphrases; unique per system.

• Company-managed devices (or BYOD enrolled in MDM); encryption at rest/in transit.

• VPN on public Wi-Fi; no personal cloud drives for Company data.

• Classification: Public / Internal / Confidential / Restricted—label & handle accordingly.

• Report phishing/malware/mis-sends immediately (≤24h) to security@….
   

17.7) Acceptable Use of IT Systems

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• Business use first; limited personal use if lawful and not disruptive.

• Prohibited: unlicensed software, torrenting, scraping that violates T&Cs, bypassing security, using personal email for work, feeding confidential data to unapproved AI tools.

• Monitoring/audits may occur where lawful; no expectation of privacy on Company systems.
   

17.8) Social Media & External Communications

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• Do not speak for Mezzarion unless authorised; media inquiries → Communications/Legal.

• Never disclose confidential info; no defamatory, discriminatory, or harassing content.

• Personal posts: be professional; use disclaimers when discussing industry topics.
   

17.9) Health, Safety & Environment (HSE)

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• Follow safety rules, training, PPE; stop-work authority if unsafe.

• Report incidents/near-misses immediately; cooperate with investigations.

• Travel safety: follow risk advisories and pre-trip requirements.

• Drugs/alcohol: prohibited if impairing safety/performance; testing where lawful.
   

17.10) Travel & Expenses

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• All travel pre-approved; book via Company channels.

• Class of travel: Economy by default; Business Class may be approved for flights >6 hours or specified roles (documented exception).

• Hotels/per-diem within caps; no luxury/spa add-ons.

• Itemised receipts; submit within 10 business days of return.

• No reimbursement for fines, status upgrades, or items violating Gifts/ABAC.
   

17.11) Disciplinary & Grievance (Global Framework)

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• Misconduct (examples): fraud, bribery, harassment, discrimination, threats/violence, data breaches, COI, insubordination, repeated absence/lateness, policy breaches.

• Process: notice → fair hearing with representation → written outcome → right of appeal (adapted to local law).

• Sanctions up to and including termination (summary for gross misconduct where lawful).

• Grievances: manager → HR → escalation panel; no retaliation.
   

Policy Owners:

• Compliance (ABAC, Gifts, Trade, AML) | Privacy (Data Protection) | Security (InfoSec/AUP) | People & Culture (Disciplinary/Grievance, Travel & Expenses, HSE, Social Media).
  Review Cycle: at least annually or upon legal change. Attestations: annual training + acknowledgments.

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17A — Contractors, Consultants & Service Providers

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1. Scope & Status

   • Independent contractors, consultants, and service providers (“Contractors”) are not employees of Mezzarion and do not receive employee benefits or statutory entitlements.

   • Contractors are engaged under independent service agreements and must respect the independent nature of their status.

2. Applicability of Policies

   • Contractors must comply with the following mandatory Company policies:

     • Code of Conduct & Ethics

     • Anti-Bribery & Corruption (ABAC) Standard

     • Gifts & Hospitality Standard

     • Trade Controls & Sanctions Standard

     • Anti-Money Laundering (AML) & Know Your Customer (KYC) Standard

     • Privacy & Data Protection Policy

     • Information Security Policy (including Password/MFA, Classification, Incident Response)

     • Acceptable Use of IT Systems

     • Social Media & External Communications Policy

     • Health, Safety & Environment (HSE) Policy

   • Mezzarion may update these policies from time to time. Contractors are required to stay compliant with the latest versions.

3. Conduct & Representation

   • Contractors must act professionally and in Mezzarion’s best interests when representing the Company.

   • They must not misrepresent their authority, commit the Company to obligations without written approval, or engage in activities that may harm the Company’s reputation.

4. Confidentiality & Data Handling

   • All confidential, proprietary, or personal data accessed in the course of providing services must be handled in accordance with the Confidentiality Clause in the contract and the Privacy & Data Protection Policy.

   • Contractors must report any data breaches or suspected security incidents immediately.

5. Compliance & Ethics

   • Contractors must not offer, give, solicit, or accept any form of bribe, facilitation payment, or improper advantage.

   • All gifts or hospitality received or offered in connection with Mezzarion business must be recorded and declared, in line with Company thresholds.

   • Contractors must comply with applicable trade restrictions, export controls, and sanctions.

6. Discipline & Consequences

   • Contractors do not follow the employee disciplinary process.

   • Breach of policies or misconduct may result in:

     • Immediate termination of contract;

     • Withholding of unpaid fees related to non-compliant work;

     • Blacklisting from future engagements; and/or

     • Referral to authorities where law has been broken.

7. Grievances & Escalations

   • Contractors may raise concerns or grievances through the designated contract manager or via compliance@mezzarion.com.

   • Contractors are not entitled to the employee grievance process, but good-faith concerns will be investigated fairly.

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18) Remote & Hybrid Work

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• Eligibility by role, performance, security, and legal constraints.

• Secure workspace, stable connectivity, availability during core hours, accurate timekeeping.

• Lawful audits for security compliance may apply.

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19) Exit & Post-Employment Obligations

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• Follow notice periods (contract/annex).

• Complete handover, return all assets, access revoked.

• Confidentiality and restrictive covenants continue as agreed and permitted by law.

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20) Governance, Changes & Exceptions

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• Ownership: People & Culture with Legal/Compliance.

• Amendments: Mezzarion may amend, suspend, or withdraw policies (subject to local law/consultation where required).

• Exceptions: Written approval by HR + Legal only.

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21) Acknowledgment

All employees must sign the Employee Handbook Acknowledgment confirming they have read, understand, and will comply with this Handbook and their Jurisdiction Annex.