ANTI-CORRUPTION POLICY

Last Updated: July 26, 2026

We are committed to transparency. This policy protects you from financial exploitation, safeguards personal security and establishes clear accountability guidelines. We ensure our platform runs on fairness rather than bribery, extortion, or backroom deals.

QZZON Group is committed to conducting business with the highest standards of integrity and ethics. This Anti-Corruption Policy applies to all employees, officers, directors and third-party partners globally.

1. Purpose & Scope
This policy establishes a zero-tolerance stance against bribery and corruption. It applies to all QZZON Group personnel worldwide, as well as our subsidiaries, joint ventures and third parties acting on our behalf.

We comply strictly with all applicable anti-corruption laws, including:

• US Foreign Corrupt Practices Act (FCPA)
• UK Bribery Act
• Local anti-bribery legislation in every country where we operate.

2. Prohibited Conduct
QZZON Group strictly prohibits the following acts in any business activity:

• Bribery: Offering, giving, receiving, or soliciting anything of value to influence an official action or gain an unfair business advantage.
• Kickbacks: Accepting or paying secret payments as a reward for a business transaction.
• Facilitation Payments: Making small, unofficial payments to any government officials to speed up routine, non-discretionary actions (e.g., clearing Customs or issuing permits).
• Extortion: Yielding to unauthorized demands for money under threat or coercion, unless there is an immediate risk to personal health or safety.

3. Gifts, Hospitality & Entertainment
Corporate gifts and hospitality must never be used to improperly influence a business decision. Giving or receiving gifts is only permitted if it meets all the following criteria:

• It has a legitimate, transparent business purpose.
• It is token, nominal, or of low monetary value.
• It complies with local law and the recipient’s internal rules.
• It is never given during active contract negotiations or bidding processes.

Specific Monetary Thresholds for Gifts & Hospitality
To ensure consistency, QZZON Group enforces strict financial limits on business courtesies. Any gift, meal, or entertainment that exceeds these limits requires prior written approval:

• Gifts (Given or Received): Maximum value of $900 USD (or local currency equivalent) per person, per year.
• Business Meals and Entertainment: Maximum value of $900 USD per person, per event.
• Prohibited Items: Cash, gift cards, loans, or stock options are strictly prohibited regardless of the amount.

4. Third-Party Due Diligence
QZZON Group can be held legally liable for the corrupt actions of third parties. Agents, consultants, distributors and suppliers must undergo a mandatory compliance vetting process before onboarding. All third-party contracts must include written anti-corruption clauses and audit rights.

5. Accurate Books & Records
We maintain strict financial transparency. All financial transactions must be accurately recorded in our books, with sufficient detail and supporting documentation. Falsifying records, creating off-the-books funds, or mischaracterizing expenses (e.g., hiding a bribe as a “consulting fee”) is strictly prohibited.

Political Contributions & Charitable Donations

• Political Contributions: QZZON Group does not make corporate contributions, financial or otherwise, to political parties, campaigns, or individual politicians.
• Charitable Donations: Donations made on behalf of QZZON Group must be pre-approved in writing. We only support registered non-profit organizations. Legitimate charities must undergo due diligence to ensure funds are not diverted to government officials or used as a disguised bribe.

6. Reporting & Non-Retaliation
Employees have a duty to report any suspected or actual breaches of this policy immediately. QZZON Group provides a secure, confidential reporting channel:

• Email: a3priority@gmail.com

We enforce a strict zero-retaliation policy. No employee will suffer adverse professional consequences for reporting a concern in good faith or for refusing to pay a bribe.

7. Consequences of Non-Compliance
Violations of this policy will result in disciplinary action up to and including immediate termination of employment or contract. Additionally, individuals may face severe criminal penalties, including fines and imprisonment, under international laws.

8. Regional Adjustments & Local Law
This information applies globally, but your local statutory rights always take precedence.

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