1. Purpose

Nexus Intl (“the Company”) is committed to conducting all business activities with the highest standards of integrity, transparency, and ethical behavior. This Anti Bribery & Corruption (ABC) Policy establishes clear rules and expectations to prevent bribery, corruption, facilitation payments, and other unethical practices in all forms and jurisdictions where Nexus Intl operates. This policy is designed to:

• Comply with applicable anti corruption laws and regulations worldwide
• Protect Nexus Intl’s reputation and credibility
• Promote a culture of ethical decision making and accountability

2. Scope of Application

This policy applies to:

• All employees (full time, part time, temporary, and contract)
• Directors, officers, and executives
• Consultants, advisors, interns, and volunteers
• Third parties acting on behalf of Nexus Intl, including agents, partners, distributors, resellers, contractors, and referral partners

Compliance with this policy is mandatory, regardless of location or seniority.

3. Definition of Bribery and Corruption

3.1 Bribery
Bribery is offering, giving, promising, requesting, or receiving anything of value—directly or indirectly—to improperly influence a decision, action, or outcome. Examples include:

• Cash or cash equivalents
• Gifts, travel, entertainment, or hospitality
• Discounts, commissions, or rebates not contractually approved
• Employment offers, internships, or favors
• Donations or sponsorships intended to influence decisions

3.2 Corruption
Corruption includes abuse of entrusted power for private gain, including bribery, kickbacks, fraud, embezzlement, nepotism, or conflicts of interest.

4. Zero Tolerance Policy

Nexus Intl maintains a zero tolerance approach to bribery and corruption.

• No bribes may be offered, promised, authorized, requested, or accepted
• No indirect bribes through third parties are permitted
• No facilitation payments are allowed under any circumstances

Any violation of this policy may result in disciplinary action, termination of employment or contract, and possible legal consequences.

5. Prohibition of Facilitation Payments

Facilitation payments are small, unofficial payments made to secure or expedite routine government actions. Nexus Intl strictly prohibits:

• Paying facilitation fees to government officials
• Allowing third parties to make such payments on the Company’s behalf

If an employee faces a situation involving personal safety or coercion, the incident must be reported immediately to management and the Compliance Officer.

6. Gifts, Hospitality, and Entertainment

6.1 General Principles

• Be reasonable, proportionate, and infrequent
• Serve a legitimate business purpose
• Never influence or appear to influence business decisions

6.2 Prohibited Practices

• Cash or cash equivalents (e.g., gift cards)
• Gifts or hospitality offered during contract negotiations or bidding processes
• Excessive, lavish, or inappropriate entertainment

6.3 Approval and Disclosure

• Be pre approved by management
• Be accurately recorded in company records

7. Referral Program & Anti Corruption Controls

7.1 Referral Program Overview
Nexus Intl may operate referral programs to incentivize legitimate business introductions. These programs must always comply with this ABC Policy. 7.2 Rules for Referral Fees

• Must be transparent and documented in a written agreement
• Must reflect fair market value for legitimate services
• Must never be used to disguise bribes or kickbacks

7.3 Prohibited Referral Practices

• Pay referral fees to government officials or their relatives
• Use referral arrangements to improperly influence decisions
• Make off book or undisclosed referral payments

All referral partners are subject to due diligence and ongoing monitoring.

8. Third Party Due Diligence

Nexus Intl conducts risk based due diligence on third parties, including background checks, ownership reviews, and assessment of anti corruption controls. Contracts include audit and termination rights.

9. Conflicts of Interest

Employees and representatives must avoid situations where personal interests conflict with company interests. All actual or potential conflicts must be disclosed immediately.

10. Political and Charitable Contributions

10.1 Political Contributions
Nexus Intl does not make political contributions unless explicitly approved by the Board and permitted by law. 10.2 Charitable Donations

• Be made to legitimate organizations
• Never be used to influence business or government decisions
• Be properly approved and documented

11. Accurate Books and Records

• Complete, accurate, and transparent financial records
• No false, misleading, or incomplete entries
• No undisclosed or off the books accounts

12. Reporting and Whistleblowing

12.1 Duty to Report
All employees and third parties must report suspected violations of this policy. 12.2 Reporting Channels

• Direct managers
• Compliance or Legal Department
• Email: legal@nexintl.ae

13. Training and Awareness

• Provide regular ABC training
• Maintain accessible policy documentation
• Require periodic acknowledgments of compliance

14. Monitoring, Audits, and Enforcement

Nexus Intl may conduct audits, investigate violations, and cooperate with regulatory authorities. Disciplinary measures may include termination and legal action.

15. Roles and Responsibilities

• Board & Management: Oversight and tone at the top
• Compliance Officer: Policy implementation and monitoring
• Employees & Partners: Full compliance

16. Policy Review and Updates

This policy will be reviewed periodically and updated as necessary.

17. Acknowledgment

All employees, contractors, and relevant third parties must acknowledge that they have read, understood, and agreed to comply with this Anti Bribery & Corruption (ABC) Policy.