Corporate
policies.

Version 1.0 · Effective August 2026 · Applies globally

About These Policies

Nexarq.ai is committed to operating with integrity, transparency, and respect for the law wherever we do business. This document sets out the core policies that govern how we work, how we treat one another, how we handle information, and how we expect everyone connected to Nexarq.ai to behave.

These policies apply to all directors, officers, employees, contractors, interns, and, where relevant, business partners acting on behalf of Nexarq.ai (“you” or “personnel”). They are written to be jurisdiction-neutral and reflect internationally recognized standards. Where local law imposes a stricter requirement, that stricter requirement applies.

This is a public-facing overview intended to communicate our commitments to employees, customers, partners, and the public. It is not a contract of employment and does not create contractual rights. Nexarq.ai may update these policies from time to time; the current version is always the one published at nexarq.ai.

Our Guiding Principles

• Do the right thing. Act honestly and ethically, even when no one is watching and even when it is difficult.
• Comply with the law. Follow the letter and the spirit of the laws and regulations that apply to us.
• Respect people. Treat colleagues, customers, and partners with dignity, fairness, and courtesy.
• Protect what is entrusted to us. Safeguard personal data, confidential information, and company and third-party assets.
• Speak up. Raise concerns in good faith without fear of retaliation.

1. Legal Notice & Terms of Use

This section governs use of the Nexarq.ai website and the relationship between Nexarq.ai and visitors to our online properties.

1.1 Acceptance

By accessing or using the nexarq.ai website or any Nexarq.ai product or service, you agree to these terms and to the policies referenced in this document. If you do not agree, please do not use our website or services.

1.2 Use of the Website

Content on our website is provided for general information. You may view and download material for personal, non-commercial use, provided you keep all copyright and proprietary notices intact. You may not misuse the website, attempt to gain unauthorized access, interfere with its operation, or use it for any unlawful purpose.

1.3 No Warranty & Limitation of Liability

Website content is provided “as is” without warranties of any kind, express or implied, to the fullest extent permitted by law. Nexarq.ai is not liable for any indirect, incidental, or consequential loss arising from use of the website, except where such liability cannot be excluded by law.

1.4 Third-Party Links

Our website may link to third-party sites. We do not control and are not responsible for their content or practices. Links do not imply endorsement.

1.5 Governing Law

These terms are governed by the laws of the jurisdiction in which Nexarq.ai is incorporated, without regard to conflict-of-law principles, unless a mandatory local law provides otherwise.

2. Compliance Policy

We are committed to full compliance with all applicable laws, regulations, and internationally recognized standards in every market where we operate.

2.1 Scope

This policy applies to all personnel and covers compliance across areas including corporate governance, financial integrity, competition and antitrust, sanctions and export controls, employment, health and safety, environmental regulation, consumer protection, and data protection.

2.2 Our Commitments

• Rule of law. We conduct business in accordance with the laws of every jurisdiction in which we operate.
• Accurate records. We maintain complete and accurate books, records, and accounts that fairly reflect our transactions.
• Trade controls. We comply with applicable sanctions, export controls, and anti-money-laundering requirements, and do not do business with prohibited parties.
• Fair competition. We compete vigorously but fairly and do not engage in price-fixing, bid-rigging, market allocation, or other anti-competitive conduct.
• Ongoing diligence. We assess compliance risks, train our people, and monitor and improve our controls.

2.3 Responsibilities

Every individual is responsible for understanding and following the laws and policies relevant to their role. Managers are responsible for promoting a culture of compliance and for ensuring their teams have the training and resources they need. Concerns about possible violations must be reported through the channels described in the Speak-Up & Anti-Retaliation Policy.

3. Code of Ethics & Business Conduct

Our Code of Ethics reflects the values that guide our decisions and defines the standard of conduct we expect from everyone at Nexarq.ai.

3.1 Integrity & Honesty

We are truthful in our dealings with customers, colleagues, regulators, and the public. We do not misrepresent facts, falsify records, or make promises we do not intend to keep.

3.2 Conflicts of Interest

A conflict of interest arises when personal interests interfere, or appear to interfere, with the interests of Nexarq.ai. You must avoid situations where your personal, financial, or family interests could improperly influence your judgment, and you must promptly disclose any actual or potential conflict so it can be managed. Examples include outside employment with competitors, financial interests in suppliers or customers, and hiring or supervising close relatives.

3.3 Gifts & Hospitality

Modest, occasional gifts and hospitality offered in the normal course of business may be acceptable, but nothing of value should ever be given or received to improperly influence a decision. Cash or cash-equivalents must never be given or accepted. When in doubt, decline and seek guidance.

3.4 Fair Dealing

We deal fairly with customers, suppliers, competitors, and colleagues. We do not take unfair advantage through manipulation, concealment, abuse of confidential information, or misrepresentation.

3.5 Company Assets

We protect and make responsible use of company property, funds, systems, and information, and use them for legitimate business purposes.

3.6 Accuracy of Records

All financial and business records must be accurate, complete, and maintained in accordance with applicable law and our internal controls. Falsifying records or misstating results is strictly prohibited.

4. Anti-Bribery & Anti-Corruption Policy

Nexarq.ai has zero tolerance for bribery and corruption in any form. This policy reflects the standards of leading anti-corruption laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

4.1 Prohibited Conduct

You must never, directly or through a third party, offer, promise, give, request, accept, or receive any bribe or improper advantage—whether money, gifts, favors, or anything else of value—to obtain or retain business or to influence any decision.

• Bribery of officials. Offering or giving anything of value to a government official, political party, or candidate to influence an official act is prohibited.
• Commercial bribery. The same prohibition applies to private-sector dealings with customers, suppliers, and partners.
• Facilitation payments. So-called “grease” or facilitation payments to expedite routine actions are prohibited, regardless of local custom.
• Kickbacks. Returning a portion of a payment as a reward for making or arranging business is prohibited.

4.2 Third Parties

We may be held responsible for the acts of agents, consultants, distributors, and other intermediaries. We conduct appropriate due diligence on third parties who act on our behalf, and we require them to uphold anti-corruption standards equivalent to our own.

4.3 Gifts, Hospitality & Donations

Gifts, entertainment, sponsorships, charitable contributions, and political donations must be reasonable, transparent, properly recorded, and never used to disguise a bribe. Political contributions on behalf of Nexarq.ai require prior approval.

4.4 Record-Keeping

All payments and expenses must be accurately recorded with sufficient detail. No undisclosed or unrecorded accounts may be maintained for any purpose.

4.5 Reporting

Anyone who becomes aware of actual or suspected bribery or corruption must report it immediately through the channels in the Speak-Up & Anti-Retaliation Policy. Reports made in good faith will be protected from retaliation.

5. Speak-Up & Anti-Retaliation (Whistleblower) Policy

We encourage everyone to raise concerns about conduct that may be illegal, unethical, or contrary to our policies. Nexarq.ai strictly prohibits retaliation against anyone who speaks up in good faith.

5.1 What to Report

You should report any genuine concern, including suspected fraud, bribery or corruption, financial misconduct, discrimination or harassment, data protection breaches, health and safety risks, conflicts of interest, or any other breach of law or of these policies.

5.2 How to Report

• Your manager or leadership. In most cases, the quickest route is to raise the concern with your manager or another leader you trust.
• Compliance / Ethics contact. You may contact the compliance or ethics function directly at the address published on nexarq.ai.
• Confidential channel. Where available, you may use a confidential or anonymous reporting channel.

5.3 Confidentiality

We handle reports as confidentially as possible, sharing information only with those who need it to investigate and respond. Where permitted, you may report anonymously; providing your identity helps us investigate more effectively.

5.4 Non-Retaliation

No one will be dismissed, demoted, disciplined, harassed, or otherwise disadvantaged for raising a concern in good faith or for cooperating with an investigation. This protection applies even if the concern turns out to be mistaken, provided it was raised honestly. Retaliation is itself a serious violation of these policies and will be investigated and addressed.

5.5 Investigation & Good Faith

All reports are taken seriously and investigated promptly, fairly, and impartially. Knowingly making a false or malicious report, however, is a breach of these policies. Nothing in this policy limits your right to report to a regulator or law-enforcement authority.

6. Anti-Harassment, Anti-Discrimination & Respectful Workplace Policy

Nexarq.ai is committed to a workplace free of harassment, discrimination, and bullying, where everyone is treated with dignity and respect.

6.1 Equal Opportunity & Non-Discrimination

We provide equal opportunity in recruitment, employment, development, and advancement. We do not tolerate discrimination based on race, color, ethnicity, national origin, religion, age, sex, gender, gender identity or expression, sexual orientation, marital or family status, pregnancy, disability, genetic information, veteran status, or any other characteristic protected by applicable law.

6.2 Harassment

Harassment is any unwelcome conduct—verbal, physical, visual, or online—that creates an intimidating, hostile, degrading, or offensive environment, or that is made a condition of employment. Harassment based on any protected characteristic is prohibited.

6.3 Sexual Harassment

Sexual harassment is specifically prohibited. It includes unwelcome sexual advances, requests for sexual favors, and other unwelcome conduct of a sexual nature, whether or not it is directed at a particular person. This covers two common forms:

• Quid pro quo. Where submission to, or rejection of, sexual conduct is used as a basis for employment decisions such as hiring, promotion, pay, or continued employment.
• Hostile environment. Where unwelcome sexual conduct is severe or pervasive enough to create an intimidating, hostile, or offensive working environment.

Examples include unwanted touching; sexual comments, jokes, or gestures; sharing sexually explicit images or messages; repeated unwelcome advances; and sexual coercion. This applies in the office, at work-related events, during travel, and across all digital channels including chat, email, and video.

6.4 Bullying

Bullying—repeated unreasonable behavior that humiliates, intimidates, or undermines a person—is not tolerated, regardless of whether it targets a protected characteristic.

6.5 Reporting & Response

If you experience or witness harassment or discrimination, report it promptly to your manager, human resources, or through the Speak-Up channels. We investigate complaints promptly, fairly, and confidentially, take appropriate corrective action, and prohibit retaliation against anyone who reports in good faith or participates in an investigation. Substantiated violations may result in disciplinary action up to and including termination.

7. Data Protection & Privacy Policy

We respect the privacy of our customers, employees, and partners, and we handle personal data responsibly, lawfully, and transparently, consistent with internationally recognized standards such as the EU/UK General Data Protection Regulation (GDPR).

7.1 Principles

• Lawfulness, fairness & transparency. We process personal data only where we have a valid legal basis and we tell people how their data is used.
• Purpose limitation. We collect personal data for specified, legitimate purposes and do not use it in incompatible ways.
• Data minimization. We collect only what we need.
• Accuracy. We keep personal data accurate and up to date.
• Storage limitation. We keep personal data only as long as necessary.
• Integrity & confidentiality. We protect personal data with appropriate technical and organizational security measures.
• Accountability. We take responsibility for how we handle data and can demonstrate our compliance.

7.2 What We Collect

Depending on your relationship with us, we may process contact details, account and profile information, transaction and usage data, device and log information, and communications. We describe the specific categories and purposes in the privacy notices provided at the point of collection.

7.3 How We Use Data

We use personal data to provide and improve our products and services, communicate with you, ensure security, meet legal obligations, and, where permitted, for marketing you can opt out of. We do not sell personal data.

7.4 Sharing & International Transfers

We share personal data only with service providers and partners who are bound by appropriate confidentiality and security obligations, or where required by law. When we transfer data across borders, we use appropriate safeguards recognized under applicable data protection law.

7.5 Your Rights

Subject to applicable law, individuals may request access to their personal data and may request that it be corrected, deleted, or restricted; may object to certain processing; may request data portability; and may withdraw consent. To exercise these rights, contact us using the details published at nexarq.ai. You also have the right to lodge a complaint with a data protection authority.

7.6 Security & Breach Response

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, or misuse. In the event of a personal data breach, we respond promptly, assess the risk, notify affected individuals and regulators where required, and take steps to prevent recurrence.

7.7 Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations, resolve disputes, and enforce our agreements, after which it is securely deleted or anonymized.

8. Intellectual Property Policy

Intellectual property is among Nexarq.ai's most valuable assets. We protect our own IP and respect the IP rights of others.

8.1 Ownership of Company IP

All intellectual property created by personnel in the course of their work for Nexarq.ai—including software, source code, designs, inventions, content, documentation, trademarks, and know-how—is the property of Nexarq.ai to the fullest extent permitted by law, and personnel assign such rights to the company where required.

8.2 Protecting Our IP

Our trademarks, logos, product names, and brand assets may not be used without authorization. Our proprietary software, algorithms, and materials are protected by copyright, trade secret, and other laws and may not be copied, distributed, or reverse-engineered except as expressly permitted.

8.3 Respecting Third-Party IP

We do not knowingly infringe the intellectual property rights of others. Personnel must not use third-party software, images, text, music, or other materials without a valid license, and must comply with the terms of any open-source or third-party licenses we rely on.

8.4 Confidential Information & Trade Secrets

Confidential information—whether ours or entrusted to us by customers and partners—must be protected, used only for authorized purposes, and never disclosed without authorization. These obligations continue after your relationship with Nexarq.ai ends.

8.5 Reporting Infringement

If you believe content on our website or in our products infringes your intellectual property, or if you become aware of infringement of Nexarq.ai IP, please contact us using the details at nexarq.ai so we can investigate and respond appropriately.

9. Information Security & Acceptable Use Policy

Protecting our systems and information is everyone's responsibility.

9.1 Acceptable Use

Company systems, devices, networks, and accounts are provided for legitimate business purposes. Users must protect their credentials, use strong authentication, avoid installing unauthorized software, and refrain from any use that is unlawful, harassing, or that compromises security.

9.2 Safeguards

We apply appropriate access controls, encryption, monitoring, and other safeguards, and we require personnel to follow security procedures, report suspected incidents promptly, and complete required security training.

9.3 Confidentiality of Data

Access to confidential and personal data is limited to those with a legitimate business need. Data must be handled in line with the Data Protection & Privacy Policy.

10. Additional Policies

10.1 Health, Safety & Environment

We are committed to providing a safe and healthy workplace, complying with applicable health and safety laws, and reducing the environmental impact of our operations.

10.2 Modern Slavery & Human Rights

We respect internationally recognized human rights and have zero tolerance for forced labor, human trafficking, and child labor in our operations and supply chains. We expect our partners to uphold the same standards.

10.3 Diversity, Equity & Inclusion

We foster an inclusive culture where diverse backgrounds and perspectives are valued, and we work to ensure fair and equitable treatment for everyone.

10.4 Insider Trading

Personnel must not trade in securities on the basis of material, non-public information, or share such information with others who might trade on it.

10.5 Social Media & External Communications

When speaking publicly or on social media, personnel must not disclose confidential information, must be clear they speak for themselves unless authorized, and must uphold the reputation of Nexarq.ai and treat others respectfully.

10.6 Sanctions & Export Controls

We comply with applicable economic sanctions and export-control laws and do not transact with sanctioned individuals, entities, or territories.

11. Governance, Enforcement & Contact

11.1 Compliance with Policies

Compliance with these policies is a condition of working with Nexarq.ai. Violations may result in disciplinary action up to and including termination of employment or engagement, and may be referred to authorities where the law requires.

11.2 Review & Updates

These policies are reviewed periodically and updated as our business, and the legal landscape, evolve. The current version is always the one published at nexarq.ai. Material changes will be communicated as appropriate.

11.3 Questions & Reporting

If you have questions about these policies, wish to seek guidance, or need to report a concern, please contact us at legalethicsprivacy@nexarq.ai.

11.4 External Counsel

Satatham Kritam Legal Solutions LLP (SKLS) serves as Nexarq.ai's external counsel for legal, compliance, and ethics matters.

© 2026 Nexarq.ai.