Official Digital Presence & Institutional Communication Statement

Version 1 | Approved 18 May 2026

GMA Consultancy S.A.R.L (“GMA”) issues this statement to define its official digital presence and the standards governing its conduct across digital and social media platforms.

1. Purpose and Scope

GMA Consultancy (Governance, Monitoring & Advisory) S.A.R.L issues this statement to: (a) define clearly its official digital presence; (b) explain the purpose of its engagement on digital platforms and social media; (c) establish the boundaries between GMA’s institutional voice and the personal communications of the individuals associated with it; (d) set out GMA’s standards for the management of comments and third-party content on its official channels; and (e) establish the legal framework governing GMA’s rights and remedies in respect of its digital presence, intellectual property, and institutional reputation.

This statement applies to all stakeholders who engage with GMA’s content online, including clients, partners, employees, professionals, and the general public. By interacting with GMA’s official digital channels, all parties acknowledge and agree to the standards and terms set out in this statement.

2. GMA’s Institutional Commitments

In issuing this statement, GMA Consultancy reaffirms the following commitments that govern its institutional conduct and digital communications:

• Integrity: GMA’s institutional positions and communications are governed exclusively by applicable laws, professional ethics, compliance standards, and governance best practices.
• Transparency: GMA communicates clearly about the boundaries between its institutional voice and the personal voices of individuals associated with the firm.
• Respect for the Law: GMA operates in full compliance with Lebanese law and applicable international standards in all of its activities, including its digital communications.
• Accountability: GMA holds itself to the same governance standards it advocates for its clients. This statement is one expression of that commitment.
• Professionalism: All content published on GMA’s official digital channels is reviewed to ensure it meets GMA’s standards of accuracy, relevance, and professional quality.
• Fairness: GMA’s approach to the personal digital conduct of individuals associated with it is governed by the principles of proportionality, due process, and respect for individual rights — as set out in Section 5 of this statement.
• Dignity of Engagement: GMA engages with its digital community in a spirit of professional respect. GMA does not engage in public confrontation, does not respond to bad faith with bad faith, and does not allow its official channels to be used as a platform for harm.

3. GMA’s Official Digital Presence

GMA Consultancy is present digitally — across the internet and on social media platforms — exclusively through its official channels. The following table lists GMA’s authorised digital channels.

4. Purpose of GMA’s Engagement on Social Media

GMA Consultancy uses its official social media channels to deliver value to multiple audiences: the general public, the professional community, and current and prospective clients. GMA’s social media engagement serves the following purposes exclusively.

4.1 Public Awareness on Financial Crime Risks

GMA is committed to raising awareness of financial crime risks among the general public — not limited to any specific sector or professional background. Through its digital platforms, GMA aims to:

• Inform people about the financial crime risks they may be exposed to in their daily lives, professional activities, and business dealings.
• Provide accessible, practical guidance on the preventive measures individuals and organisations can implement to reduce their exposure to financial crime risks.
• Share clear and actionable information on the steps that should be taken if an individual or organisation has already been exposed to or affected by financial crime.

GMA believes that financial crime awareness is a shared responsibility. Informed citizens, consumers, and businesses are the first line of defence against fraud, money laundering, sanctions violations, and related risks.

4.2 Experience Sharing with the Professional Community

GMA uses its digital presence to contribute to the professional development of the compliance and financial crime prevention community, with particular focus on the next generation of professionals. This includes:

• Sharing practical insights, lessons learned, and professional experience accumulated over more than 27 years in compliance, risk management, AML/CFT, and financial crime prevention across Lebanon and the region.
• Supporting young professionals and students building a career in compliance, governance, and financial crime prevention — providing guidance, perspective, and encouragement through publicly accessible content.
• Facilitating professional dialogue and knowledge exchange with peers, specialists, and institutions operating in the same field.

GMA’s contribution to professional knowledge-sharing reflects its commitment to strengthening the compliance culture across the region — one professional at a time.

4.3 The Story Behind GMA

As part of its commitment to transparency and authentic engagement with the public, GMA publishes a series of short video content designed to give its audience a genuine understanding of who GMA is and what drives its work. This content series covers the experience behind GMA, the story behind the name, the story behind the logo, the story behind establishing GMA, and GMA’s services.

This content is produced and published exclusively through GMA’s official channels and is subject to the same standards of accuracy, professionalism, and quality that govern all of GMA’s communications.

4.4 Marketing of GMA’s Professional Services

GMA Consultancy uses its official digital channels to communicate the scope, value, and availability of its professional services. This includes publishing information about GMA’s service offerings, sharing client-relevant insights and regulatory updates, announcing new services and advisory tools, and inviting current and prospective clients to engage with GMA directly. All service-related communications reflect GMA’s institutional position and are subject to GMA’s standards of professional accuracy and integrity.

4.5 Community Initiative & Corporate Social Responsibility

GMA Consultancy uses its digital presence to fulfil its community initiative commitments and to communicate its activities under its Corporate Social Responsibility (CSR) framework. This includes supporting verified medical fundraising causes, providing visibility to young professionals, and empowering individuals — particularly women — through professional visibility and market access.

GMA’s community initiative activities are implemented in full compliance with GMA’s published CSR & Governance Framework and Governance Notices, both available at www.gmaconsultancy.com.

5. Separation of Institutional and Personal Voices

GMA Consultancy is an institution. The individuals associated with GMA — including its founder, general manager, employees, managers, strategic partners, clients, and third-party service providers — are each independent persons with their own rights to freedom of expression.

This applies to, but is not limited to, personal expressions on political party affiliation, sectarian or religious positions, social or civic commentary, economic or fiscal policy positions, foreign policy or geopolitical views, and any other matter of personal opinion or belief.

GMA respects the right of every individual to hold and express personal views. This statement establishes a professional boundary — it does not restrict personal freedom of expression. Personal views expressed on personal platforms are the sole responsibility of the individual concerned.

This dissociation applies equally to the founder and general manager of GMA Consultancy, whose personal digital presence and personal statements do not constitute official GMA positions unless explicitly published through GMA’s official channels as defined in Section 3 of this statement.

5.1 GMA’s Commitments to Individuals Associated with the Company

5.1.1 No Disciplinary Action for Personal Expression

Subject to the conditions set out in Section 5.2, GMA Consultancy commits that it will not take any disciplinary measure, adverse action, or adverse professional consequence against any individual solely on the basis of content posted on that individual’s personal social media accounts or personal digital channels.

5.1.2 No Surveillance of Personal Social Media Accounts

GMA Consultancy does not conduct surveillance of, or engage in ongoing and intentional monitoring of, the personal social media accounts of any individual associated with the company. GMA does not systematically review, track, or record the personal digital activity of its employees, managers, partners, clients, or service providers.

Employees hold, sign, and renew annually the following governance instruments:

5.1.3 Protection of Professional Relationships

GMA Consultancy commits that the personal social media activity of any individual associated with GMA will not, in itself, be used as grounds to terminate, diminish, or otherwise impair the professional relationship between GMA and that individual — provided the conditions set out in Section 5.3 are met.

5.2 Standards Applicable to Personal Digital Conduct

The protections in Section 5.1 protect personal opinion, belief, and expression — they do not protect conduct that breaks the law or that runs contrary to the values GMA is built on. This section defines both boundaries concretely, so that no individual associated with GMA is left guessing where the line sits.

5.2.1 Compliance with Applicable Law

Nothing in this statement protects content that violates applicable law. Individuals associated with GMA remain personally and fully responsible for the legality of their own personal digital conduct, in the same way any private citizen is.

5.2.2 GMA’s Values Standard

Separately from legality, GMA Consultancy is built on a defined set of institutional values, and expects the personal conduct of individuals associated with it — to the extent that conduct is publicly visible and connects that individual to GMA — not to actively work against those values. The following, in particular, are treated as contrary to GMA’s values:

• Harassment, discrimination, or conduct that violates the human rights or dignity of any individual or group;
• Publishing, sharing, or encouraging abusive, cruel, or degrading content directed at people, animals, the environment, or the orderly functioning of markets;
• Threatening any individual or organisation; and
• Violating another person’s privacy, including through unauthorised disclosure of their personal information or private communications.

This values standard does not extend to, and must never be applied to restrict, an individual’s personal political opinion, religious or ideological belief, or lawful advocacy and criticism — including criticism of public figures, institutions, companies, or GMA’s own clients, expressed as personal opinion. GMA does not require its people to justify what they believe. It does ask that where a person publicly and specifically accuses a named party of wrongdoing in a manner that could reasonably be understood as connected to GMA — for example, through that person’s identified professional affiliation — they be able to substantiate the factual claims underlying that accusation if GMA’s own credibility is put at risk as a result. This is a narrow expectation of credibility where GMA’s name is implicated, consistent with the conditions in Section 5.3, and not a general licence for GMA to question personal opinion.

5.2.3 Identifying Personal Views as Personal

Where an individual’s social media account, profile, or public presence identifies their affiliation with GMA — whether by naming GMA as an employer, using a GMA-related title, or otherwise — that individual is expected to make reasonably clear, through their account bio, profile, or similar means, that the views they express are personal and do not represent GMA’s institutional position. This is a reasonable, practical expectation attached to identifying oneself publicly with GMA — it does not require a disclaimer on every individual post.

5.2.4 Personal Content Is Not a Workplace Topic

The personal social media content of any individual — whether their own or a colleague’s — is not to be discussed, shared, or raised within GMA’s premises, at a client’s premises, or in any communication with a client. Personal digital conduct is exactly that: personal, and it has no place in GMA’s professional environment or its client relationships.

5.2.5 Equal Treatment Regardless of Background

No individual associated with GMA may treat a colleague or a client differently on the basis of that person’s political affiliation, religious belief, or ethnic background. This applies to every professional interaction, regardless of what that colleague or client may have expressed on their own personal platforms.

5.3 Conditions for the Protections in Section 5.1 to Apply

The commitments set out in Section 5.1 apply provided all of the following conditions are met:

• Separation of identity: The individual’s personal content does not use GMA’s name, logo, branding, professional title, or institutional affiliation in a manner that creates, implies, or reasonably risks the impression that the content represents GMA’s institutional position.
• No attribution to GMA: The individual has not represented, stated, or implied — whether directly or through context — that the views expressed on their personal platforms are shared by, endorsed by, or reflective of GMA Consultancy’s position.
• No material impact on GMA’s credibility: The content does not materially undermine GMA’s professional credibility, transparency, market reputation, or its standing with clients, strategic partners, regulatory counterparts, or the general public.
• No violation of law or GMA’s values: The content does not constitute a serious violation of applicable Lebanese law or applicable international standards, does not breach the values standard set out in Section 5.2.2, and does not expose GMA — through its association with the individual — to legal liability, regulatory action, or sanctions-related risk.
• No serious risk to GMA’s relationships: The content does not create a serious and credible risk of significant reputational, regulatory, or commercial harm to GMA’s relationships with its clients, strategic partners, or institutional counterparts.

To be clear about what this last condition does, and does not, mean: if a client pressures GMA to discipline or dismiss an individual because of something that individual expressed in a personal capacity on their own platform, GMA’s response is to decline or end that client relationship — not to take action against the individual. A client’s discomfort with someone’s personal views is never, by itself, the commercial harm this condition addresses, and it will never be treated as satisfying this condition.

What this condition is aimed at is different: an individual using their position or access at GMA to expose, disclose, or reference sensitive client information on their personal platforms — including information that is confidential, or that the individual misrepresents, misinterprets, or presents out of context in a way that damages GMA’s relationship with the client concerned. That is a breach of the confidentiality obligations already owed under GMA’s Code of Conduct, independent of any question of personal opinion, and it is conduct of this kind — not a client’s reaction to someone’s personal views — that this condition exists to reach.

6. Management of Comments and Third-Party Content

GMA Consultancy welcomes constructive engagement, professional dialogue, and feedback on its official social media channels. GMA’s digital platforms are intended to be purposeful, respectful, and professionally relevant spaces — consistent with the values of integrity, transparency, and professionalism that govern all of GMA’s institutional conduct.

GMA does not engage in disputes for the purpose of public confrontation, and does not allocate institutional time or resources to responding to content whose sole purpose is to cause harm, spread misinformation, or damage GMA’s reputation. Where such content is identified, GMA will take the appropriate measures as set out in this section — calmly, proportionately, and in accordance with applicable law and platform standards.

6.1 Community Standards

By interacting with GMA Consultancy’s official social media accounts — including commenting on, sharing, tagging, replying to, or otherwise engaging with GMA’s published content — all individuals agree to conduct themselves in accordance with the following standards:

• Respect and professionalism: Engagement must be respectful toward GMA, toward GMA’s associates, and toward other community members. Personal attacks, insults, threats, harassment, intimidation, and bullying are not acceptable.
• Accuracy: Comments, posts, and shared content that tag or reference GMA must not contain false statements of fact, unproven accusations, fabricated claims, or deliberately misleading information about GMA, its founder, its employees, its services, or its clients.
• Relevance: Content posted on or directed at GMA’s official channels should be relevant to the subject matter of GMA’s work. Spam, promotional content for third parties, repeated off-topic posts, and content designed to derail professional discussion will be moderated.
• No hate speech or discrimination: Content discriminatory on the basis of religion, ethnicity, nationality, race, gender, gender identity, sexual orientation, or any other protected characteristic will not be tolerated.
• No impersonation or misrepresentation: Posting under a false identity, impersonating GMA, GMA’s founder, or any GMA associate, or creating accounts designed to mislead others into believing they represent GMA, is strictly prohibited.
• No exploitation of GMA’s platforms: GMA’s official channels may not be used to solicit commercial transactions, promote third-party products or services, or redirect GMA’s audience to external platforms without GMA’s explicit authorisation.

6.2 How GMA Handles Comments and Third-Party Content

GMA applies a tiered, proportionate approach to the management of comments and third-party content. Moderation decisions are guided by the nature and intent of the content, not by a desire to suppress legitimate criticism or professional debate.

6.3 GMA’s Reserved Rights

GMA Consultancy reserves the following rights in the management of its official social media channels, exercisable at GMA’s sole discretion and without prior notice:

• To remove, hide, or delete any comment, tag, post, reply, or shared content that does not comply with GMA’s community standards as set out in Section 6.1.
• To block or ban any user from GMA’s official channels who repeatedly or seriously violates GMA’s community standards.
• To report any content or account to the relevant social media platform where the content constitutes harassment, false information, impersonation, hate speech, or any other violation of that platform’s terms of service.
• Not to respond to, engage with, or allocate resources to comments, posts, or campaigns that GMA determines to be in bad faith, designed solely to cause harm, or serving no legitimate constructive purpose.
• To preserve, document, and archive any content that GMA considers potentially defamatory, legally actionable, or reputationally harmful — prior to any removal action.
• To take all available legal measures — including issuing formal notices, pursuing platform content removal procedures, and initiating legal proceedings — in response to content that constitutes defamation, harassment, false accusations, impersonation, or any other tortious or criminal conduct under applicable Lebanese law and international standards.

6.4 Evidence Preservation and Documentation

6.5 Distinction Between Criticism and Defamation

GMA Consultancy recognises and respects the right of any individual to express a genuine professional opinion, a dissatisfied client experience, or a substantive critique of GMA’s work or positions. Such expression — even when critical or unflattering — is legally protected and does not constitute defamation. GMA will not seek to silence legitimate criticism.

Defamation is a different and legally distinct category. It occurs when a person publishes a statement that is: (a) a false statement of fact — not an opinion; (b) published to third parties; (c) harmful to GMA’s reputation; and (d) made without reasonable basis for believing it to be true. The publication of false factual claims about GMA’s services, professional conduct, regulatory standing, founder’s credentials, or business practices — whether on social media, review platforms, or any other digital channel — constitutes potential defamation and will be addressed accordingly.

6.6 Negative Posts Tagging GMA on External Platforms

GMA monitors mentions of its name and official accounts across social media platforms. Where GMA is tagged in, mentioned in, or associated with content published on platforms it does not control — including personal accounts, news commentary platforms, review sites, and third-party websites — GMA applies the same tiered approach set out in Section 6.2.

GMA will not be drawn into public exchanges initiated for the purpose of reputational damage. GMA’s institutional response to such content — where a response is warranted — will be measured, factual, and professional. Where the content crosses legal thresholds, GMA will act through legal channels rather than through public argument.

6.7 Limitation of Liability for Third-Party Content — and GMA’s Official Endorsement Protocol

GMA Consultancy is not liable for the content of any post, comment, or communication published by a third party on GMA’s digital platforms, in GMA’s comment sections, or tagging GMA’s accounts. The presence of third-party content on GMA’s platforms does not constitute GMA’s endorsement of or association with that content. GMA’s obligation is limited to moderating content in accordance with its published Community Standards (Section 6.1) within a reasonable timeframe upon becoming aware of it.

GMA does not endorse, approve, validate, or associate itself with the content of any post, article, claim, or statement published by any third party — including content that is complimentary, commercially favourable, or professionally aligned — unless GMA has explicitly and formally endorsed that content through one of the mechanisms below.

6.8 Digital Conduct Complaints Procedure

GMA Consultancy is committed to accountability. Any person — natural or legal — who believes that GMA has acted in a manner inconsistent with the standards set out in this statement, or who wishes to raise a concern regarding GMA’s digital conduct, is invited to submit a formal complaint directly to GMA before escalating to any external authority, platform, or public forum.

7. Intellectual Property Protection & Creation Date Record

8. Governing Law, Jurisdiction & Effective Date

8.1 Effective Date and Review

This statement (GMA-STMT-2026-001, Version 1) is effective from 18 May 2026, the date of its publication on GMA Consultancy’s official website at www.gmaconsultancy.com and on all official GMA social media channels listed in Section 3.

This statement will be reviewed periodically and updated as necessary to reflect changes in GMA’s digital presence, governance framework, intellectual property portfolio, or applicable law. The version number and last-amendment date on the face of this document will be updated with each revision.

Stakeholders with questions regarding this statement, wishing to verify the authenticity of any communication attributed to GMA Consultancy, or wishing to submit a Digital Conduct Complaint, are invited to contact GMA directly:

Approval

This Official Digital Presence & Institutional Communication Statement is approved and issued by: