Anti-Bribery Policy

1. Purpose

Nakreous Digital Solutions, Inc. (referred to as "Nakreous" or "the Company") is committed to conducting business ethically and honestly and is committed to implementing and enforcing systems that ensure bribery and corruption are prevented. We have zero tolerance for bribery and corrupt activities, and we pledge to act professionally, fairly, and with integrity in all business dealings and relationships wherever we operate.

2. Scope

This policy applies to all employees, officers, consultants, contractors, agents, and any other third-party representatives (collectively referred to as "personnel") working on behalf of Nakreous, regardless of their location.

3. Definition of Bribery and Corruption

Bribery refers to the offering, promising, giving, accepting, or soliciting an advantage as an inducement for illegal, unethical action or a breach of trust. This can include cash, gifts, hospitality, expenses, reciprocal favors, or anything else of value.

Corruption is the abuse of entrusted power for private gain. It can take many forms and vary in degree, from minor uses of influence to institutionalized bribery.

4. Policy Statements

1. Prohibition of Bribery and Corruption: Nakreous strictly prohibits the giving, offering, receiving, or soliciting bribes or any other forms of improper payments or advantages, whether directly or through third parties, in any form.

2. Gifts and Hospitality: Gifts and hospitality may only be offered or accepted by this policy. They must be reasonable and appropriate and cannot influence or appear to influence decision-making. All gifts and hospitality offered or received must be recorded in the Gifts and Hospitality Register.

3. Facilitation Payments: Nakreous does not make and will not accept facilitation payments or "kickbacks'' of any kind. Facilitation payments are typically small, unofficial payments to secure or expedite a routine governmental action.

4. Political Contributions: Nakreous does not make donations, whether in cash, kind or by any other means, to support any political parties or candidates.

5. Charitable Contributions: Charitable contributions and sponsorships, whether in-kind services, knowledge, time, or direct financial contributions, are acceptable. However, employees must ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

6. Third-Party Relationships: Nakreous expects all third parties, including agents, consultants, and contractors, to abide by this policy. All third-party relationships will undergo appropriate due diligence to ensure compliance with anti-bribery and anti-corruption laws.

5. Responsibilities

• Management: The leadership team at Nakreous is responsible for fostering a culture of integrity and ensuring compliance with this policy. They must also ensure that all employees know and understand the policy.

• Employees: All personnel are responsible for reading, understanding, and complying with this policy. They are also responsible for reporting any suspicions or known instances of bribery or corruption.

• Compliance Officer: The Compliance Officer is responsible for overseeing the implementation of this policy, providing guidance and training, and monitoring compliance.

6. Reporting Violations

Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Nakreous will support anyone who raises genuine concerns in good faith under this policy, even if they are mistaken. We are committed to ensuring that no one suffers any detrimental treatment due to refusing to take part in bribery or corruption or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offense has taken place or may take place in the future.

Reports can be confidentially sent to the Compliance Officer via email at compliance@nakreous.com or through the anonymous reporting hotline on our website.

7. Training and Communication

Nakreous will train all employees to ensure they understand the anti-bribery and anti-corruption laws applicable to their roles and the standards expected of them. The policy will be communicated to all third parties at the outset of our business relationship with them and as appropriate.

8. Monitoring and Review

Nakreous will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, and effectiveness. Internal control systems and procedures will be subject to regular audits to ensure they effectively counter bribery and corruption.

This policy is not part of any employee’s employment contract and may be amended at any time.

For further information or clarification on this policy, please contact our Compliance Officer at compliance@nakreous.com.

Nakreous Digital Solutions, Inc.

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