Anti-Bribery and Gifts Policy

Last Updated on July 5, 2026

Welcome to Marketeq Digital Inc. (hereinafter referred to as "Marketeq," "we," "us," or "our"). This Anti-Bribery and Gifts Policy (the "Policy") sets out Marketeq's standards regarding bribery and the giving and receiving of gifts, hospitality, and other business courtesies. Marketeq is committed to conducting business ethically and to ensuring that gifts and hospitality are never used to improperly influence business decisions. This Policy supplements our Anti-Corruption Policy and Code of Conduct. If you have any questions regarding this Policy, you may contact us at legal@marketeqdigital.com.

1. Purpose and Scope

The purpose of this Policy is to provide clear guidance on the prohibition of bribery and on the appropriate handling of gifts, hospitality, and business courtesies. This Policy applies to Marketeq's directors, officers, employees, contractors, and, where relevant, third parties acting on its behalf. It reflects our commitment to preventing bribery and to ensuring that legitimate business courtesies do not create improper influence or the appearance of it. This Policy should be read together with our Anti-Corruption Policy. Compliance with this Policy is expected of all who act for or on behalf of Marketeq.

2. Prohibition of Bribery

Marketeq prohibits bribery in all its forms. No person acting for or on behalf of Marketeq may offer, promise, give, request, or accept a bribe, meaning anything of value intended to improperly influence a business or official decision or to secure an unfair advantage. This prohibition applies to interactions with both public officials and private parties, and it applies whether the bribe is offered directly or through an intermediary. Bribery is prohibited regardless of local custom or business pressure. Marketeq maintains a zero-tolerance approach to bribery.

3. Gifts and Hospitality

Marketeq recognizes that the modest exchange of gifts and hospitality can be a legitimate part of building business relationships, provided it is reasonable, proportionate, transparent, and not intended to influence a decision improperly. Gifts and hospitality must be of an appropriate value and given openly and infrequently, and they must comply with applicable laws and the recipient's own policies. Cash or cash equivalents must not be given or accepted as gifts. Any gift or hospitality that could create an actual or perceived conflict of interest, or that could be seen as an inducement, must be avoided. When in doubt, personnel should seek guidance before offering or accepting a gift or hospitality.

4. Prohibited Gifts and Hospitality

Certain gifts and hospitality are prohibited regardless of value, including anything offered or accepted with the intent to influence a decision improperly or to obtain an unfair advantage. Lavish, extravagant, or frequent gifts and hospitality are not permitted. Gifts and hospitality must not be provided or accepted during a live tender, negotiation, or decision-making process where they could be seen to influence the outcome. Gifts and hospitality that would be illegal or that would violate the recipient's policies are prohibited. These restrictions help to ensure that business courtesies do not become improper inducements.

5. Interactions with Public Officials

Marketeq applies heightened caution to interactions with public officials, given the strict legal standards that apply. Gifts, hospitality, or anything of value offered to public officials must comply with applicable laws and the rules governing those officials, and must never be intended to influence official action improperly. Facilitation payments, meaning small payments to secure or expedite routine governmental actions, are prohibited. Personnel should seek guidance before offering anything of value to a public official. We treat interactions with public officials as areas of elevated risk.

6. Record-Keeping and Approvals

Marketeq expects gifts and hospitality given or received to be recorded accurately and, where required, approved in advance in accordance with our internal procedures. Accurate record-keeping supports transparency and helps to demonstrate that gifts and hospitality are legitimate. Personnel should follow any applicable approval and disclosure requirements before offering or accepting gifts or hospitality above any established threshold. Proper documentation is an important safeguard. We may review records of gifts and hospitality as part of our compliance activities.

7. Reporting and Non-Retaliation

Marketeq encourages personnel and third parties to report any concerns regarding bribery or the improper exchange of gifts and hospitality. Reports may be made in confidence where permitted, and Marketeq does not tolerate retaliation against anyone who reports a concern in good faith. We investigate reported concerns appropriately and take action where violations are identified. Open reporting supports the effectiveness of this Policy. We are committed to maintaining an environment in which concerns can be raised without fear.

8. Consequences of Violations

Violations of this Policy may result in disciplinary action, up to and including termination of employment or engagement, and the termination of relationships with third parties. Violations may also expose individuals and Marketeq to civil and criminal liability under applicable anti-bribery laws. We take violations of this Policy seriously and cooperate with authorities as appropriate. Compliance with this Policy protects both individuals and the organization.

9. Changes to This Policy

Marketeq reserves the right to modify or update this Anti-Bribery and Gifts Policy at any time to reflect changes in our practices or legal requirements. Any changes will become effective upon posting the revised Policy, and we encourage you to review it periodically. Where changes are material, we will endeavor to communicate them through appropriate means.

10. Contact Information

If you have any questions, concerns, or wish to report a suspected violation of this Anti-Bribery and Gifts Policy, please contact us at legal@marketeqdigital.com. We are committed to conducting business with integrity and to addressing concerns promptly and confidentially.