Anti-Corruption Policy

Last Updated on July 5, 2026

Welcome to Marketeq Digital Inc. (hereinafter referred to as "Marketeq," "we," "us," or "our"). This Anti-Corruption Policy (the "Policy") sets out Marketeq's commitment to conducting its business ethically and in compliance with applicable anti-corruption laws. Marketeq maintains a zero-tolerance approach to corruption in all its forms and requires its personnel, partners, and representatives to act with integrity. This Policy supplements our Code of Conduct and Anti-Bribery and Gifts Policy. 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 establish Marketeq's standards and expectations regarding the prevention of corruption. This Policy applies to Marketeq's directors, officers, employees, contractors, and, where relevant, its partners, agents, and other third parties acting on its behalf. It reflects our commitment to complying with applicable anti-corruption laws, including those with extraterritorial reach that may apply to our global operations. This Policy is intended to protect Marketeq, its clients, and its stakeholders from the harms associated with corruption. Compliance with this Policy is a condition of working with and for Marketeq.

2. Prohibition of Corruption

Marketeq prohibits all forms of corruption, including bribery, kickbacks, facilitation payments, and the improper use of influence, whether involving public officials or private parties. No person acting for or on behalf of Marketeq may offer, promise, give, request, or accept any improper advantage intended to influence a decision or to secure a business benefit. This prohibition applies regardless of whether the advantage is provided directly or through a third party. Marketeq maintains a zero-tolerance approach to corruption and does not accept it under any circumstances. The prohibition applies to conduct in all jurisdictions in which we operate.

3. Compliance with Anti-Corruption Laws

Marketeq is committed to complying with all applicable anti-corruption laws in the jurisdictions in which it operates. These laws may prohibit the bribery of public officials and private parties and may impose record-keeping and internal control requirements. We conduct our business in a manner designed to comply with these laws, and we expect our personnel and representatives to do the same. Where local practice conflicts with applicable anti-corruption laws or this Policy, the higher standard applies. We take our legal obligations regarding anti-corruption seriously.

4. Third Parties and Intermediaries

Marketeq recognizes that third parties and intermediaries can present significant corruption risks, and it takes reasonable steps to manage those risks. We conduct appropriate due diligence on third parties who may act on our behalf and include anti-corruption expectations in our arrangements with them where appropriate. We do not engage third parties to do indirectly what we are prohibited from doing directly. We monitor our relationships with third parties for indicators of improper conduct. Third parties acting on behalf of Marketeq are expected to comply with the standards set out in this Policy.

5. Books, Records, and Internal Controls

Marketeq maintains accurate books and records and implements internal controls designed to prevent and detect corruption. All transactions must be recorded accurately and transparently, and no undisclosed or unrecorded funds or accounts may be maintained for any purpose. Payments must be supported by appropriate documentation and made only for legitimate purposes. Our internal controls are designed to identify red flags that may indicate corrupt activity. Accurate record-keeping is an essential safeguard against corruption.

6. Reporting and Non-Retaliation

Marketeq encourages the reporting of suspected corruption and provides mechanisms through which concerns may be raised. Any person who suspects a violation of this Policy is encouraged to report it promptly, and reports may be made in confidence where permitted. Marketeq does not tolerate retaliation against any person who reports a concern in good faith. We investigate reported concerns appropriately and take action where violations are identified. A culture of open reporting supports the effectiveness of our anti-corruption efforts.

7. Consequences of Violations

Violations of this Policy are treated as serious matters and may result in disciplinary action, up to and including termination of employment or engagement, as well as the termination of relationships with third parties. Violations may also expose individuals and Marketeq to civil and criminal liability under applicable law. Marketeq cooperates with authorities as appropriate in the investigation of corruption. We are committed to holding those who engage in corruption accountable. Compliance with this Policy protects both individuals and the organization.

8. Changes to This Policy

Marketeq reserves the right to modify or update this Anti-Corruption 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.

9. Contact Information

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