Anti-Bribery & Corruption Policy

1 · Purpose

Nxt7a is committed to conducting business honestly and without bribery or corruption. This policy sets out our zero-tolerance position and what is expected of everyone who works with or for us.

2 · Scope

Applies to all employees, officers, contractors and anyone acting on Nxt7a's behalf, in every country we operate in, and to dealings with private parties, public officials, partners and Indigenous communities.

3 · Policy Statements

Zero tolerance. Nxt7a prohibits bribery and corruption in all forms. No one may offer, give, request or accept a bribe – any financial or other advantage intended to improperly influence a decision or obtain an improper advantage.

Public officials. Particular care applies to dealings with government and public officials, including grant bodies and regulators. Facilitation payments are not permitted.

Gifts and hospitality. Reasonable, proportionate and transparent gifts or hospitality may be acceptable; anything that could improperly influence, or appear to, is not. When in doubt, disclose and seek guidance.

Donations and sponsorships. Political donations are not made on Nxt7a's behalf without board approval. Charitable giving and sponsorships must be legitimate and not a disguised inducement.

Conflicts of interest. Actual or perceived conflicts must be disclosed (see the Code of Conduct).

Third parties. Partners, agents and suppliers are expected to uphold equivalent standards (see the Supplier Code of Conduct). We do not use third parties to do what we may not do ourselves.

Records. Transactions are recorded accurately and transparently; no off-book accounts or false records.

Speak up. Suspected bribery or corruption must be reported under the Whistleblower & Grievance Policy, with protection from retaliation.

4 · Roles & Responsibilities

• Everyone complies and reports concerns.
• Managers and officers model integrity and review higher-risk dealings.
• CEO / Company Secretary owns the policy and oversees serious matters with counsel ([COO or delegate]).

5 · Compliance, Monitoring & Breach

Breaches may lead to disciplinary action up to termination and referral to authorities. Bribery is a serious criminal offence with consequences for individuals and the company.

6 · Related Documents

Code of Conduct · Whistleblower & Grievance Policy · Supplier Code of Conduct · Employee Handbook.

7 · Standards Mapping

• B Corp: Governance.
• Statutory: Criminal Code Act 1995 (Cth) (including foreign bribery offences); and applicable anti-bribery laws (e.g. UK Bribery Act, US FCPA) where relevant to operations.

Review note. If Nxt7a pursues international or government grant work, confirm exposure to foreign anti-bribery regimes with [COO or delegate].

8 · Version History