Anti-Corruption & Anti-Bribery Policy

1. Our Commitment

FrontNexus is committed to conducting business with the highest standards of integrity, transparency, and accountability. We maintain a zero-tolerance approach to bribery and corruption, in any form, and in every country where we operate.

We expect ethical conduct across all business relationships. Integrity, trust, and responsible governance are fundamental to how FrontNexus works with clients, partners, instructors, suppliers, and wider society.

2. Scope and Applicability

This policy applies to:

• All employees, officers, directors, and members of the board of FrontNexus
• Contractors, instructors, consultants, and temporary workers
• Business partners, agents, suppliers, and any third parties acting for or on behalf of FrontNexus

This policy applies to all business activities, transactions, and engagements globally.

3. Prohibited Conduct

FrontNexus strictly prohibits, directly or indirectly:

• Offering, giving, soliciting, or accepting bribes or improper advantages
• Facilitation payments, kickbacks, or undisclosed benefits
• Any attempt to improperly influence decisions or secure unfair advantage
• Corrupt practices involving public officials or private counterparties

These requirements apply irrespective of local custom, market practice, or competitive pressure.

4. Gifts, Hospitality, and Business Courtesies

Gifts, hospitality, and business courtesies may be offered or accepted only where they are:

• Lawful, appropriate, and proportionate
• Infrequent and modest in value
• Intended solely to support legitimate business relationships
• Not capable of influencing—or appearing to influence—any business decision

Cash and cash-equivalent gifts are strictly prohibited under all circumstances.

5. Political and Charitable Contributions

FrontNexus does not make political contributions on behalf of the company unless explicitly permitted by law and formally approved by senior management.

Charitable contributions must be lawful, transparent, and documented, and must never be used to obtain improper influence or conceal bribery.

6. Third-Party Relationships

FrontNexus expects third parties to uphold standards equivalent to our own. We work to:

• Engage with business partners responsibly and transparently
• Apply risk-based oversight to identify and manage corruption exposure
• Include appropriate contractual expectations where relevant
• Take prompt action—including termination of relationships—if unethical conduct is identified

7. Reporting and Speaking Up

FrontNexus encourages employees and partners to report any suspected or actual violations of this policy. Reports may be made in good faith and without fear of retaliation.

All reports are treated confidentially to the extent possible and are investigated promptly, independently, and fairly.

8. Compliance and Consequences

Breaches of this policy may result in disciplinary action, termination of employment or contractual engagement, and legal action where appropriate. FrontNexus may also report matters to relevant authorities where required.

9. Policy Review

This policy is reviewed periodically to ensure continued alignment with applicable laws, regulatory expectations, and recognized global best practices.