SolvX Tech & Trade Inc. maintains an absolute zero-tolerance position on all forms of corruption, bribery, facilitation payments, and improper influence — whether offered, solicited, or received — in any jurisdiction, by any party, at any level of the supply chain or business relationship. There are no exceptions.

SECTION 1 — APPLICABLE LAWS This policy operates in full compliance with: the Corruption of Foreign Public Officials Act (CFPOA) of Canada, the Criminal Code of Canada bribery provisions, the US Foreign Corrupt Practices Act (FCPA) where applicable, the UK Bribery Act 2010 where applicable, and all other applicable anti-corruption laws and conventions.

SECTION 2 — PROHIBITED CONDUCT The following is strictly prohibited without exception: offering, promising, or giving any bribe, kickback, or improper payment to any government official, public servant, or private sector counterparty in exchange for any business advantage; soliciting or accepting any bribe or improper payment; making facilitation payments of any kind; using agents or intermediaries to channel payments that would themselves be prohibited; and disguising bribery payments as consulting fees, commissions, gifts, or entertainment.

SECTION 3 — GIFTS & HOSPITALITY SolvX permits only gifts and hospitality that are reasonable, proportionate, transparent, and consistent with normal business practice. Any gift offered to or received from a government official must be disclosed to SolvX management regardless of value. No gift may be provided during an active procurement or tender process involving the recipient.

SECTION 4 — DUE DILIGENCE ON AGENTS SolvX conducts due diligence on all agents, brokers, and intermediaries. SolvX will not engage any intermediary that refuses to provide adequate due diligence information or that exhibits indicators of corruption risk.

SECTION 5 — REPORTING Any director, employee, contractor, or counterparty who becomes aware of a potential violation must report it immediately to support@solvx.ca. SolvX will investigate all reports promptly and in confidence. Retaliation against any person making a good-faith report is strictly prohibited.

SECTION 6 — CONSEQUENCES Violations by SolvX personnel result in immediate termination and referral to law enforcement. Violations by counterparties result in immediate termination of engagement, no refund of amounts paid, and reporting to the RCMP and applicable international authorities.