1. Purpose

Apex Advisory Group Ltd (“CyberPay”) is committed to conducting business ethically and with integrity. CyberPay adopts a zero-tolerance approach to bribery and corruption in any form.

2. Scope

This policy applies to directors, officers, employees, contractors, agents, intermediaries, and third parties acting on CyberPay’s behalf (“Covered Persons”). It also sets expectations for Merchants and counterparties.

3. Prohibited Conduct (Zero Tolerance)

Covered Persons must not directly or indirectly:

• offer, promise, give, request, agree to receive, or accept a bribe or improper advantage
• make facilitation payments
• provide or accept kickbacks or improper commissions
• use third parties to do anything prohibited by this policy

4. Gifts, Hospitality, and Expenses

• Gifts/hospitality must be reasonable, proportionate, transparent, and lawful—and never intended to improperly influence a decision. CyberPay may require pre-approval or documentation for higher-risk situations.

5. Third-Party Due Diligence

• CyberPay applies risk-based due diligence to higher-risk third parties (agents, introducers, consultants, certain suppliers) and may refuse or terminate relationships where risk cannot be mitigated.

6. Recordkeeping and Controls

• CyberPay maintains accurate books and records. Off-book accounts, false invoices, disguised payments, or mischaracterised expenses are prohibited.

7. Reporting and Whistleblowing

• CyberPay may investigate and take action on any reported concerns received , including termination and referral to authorities where required.

8. Enforcement

• Violations may result in disciplinary action, termination, and legal consequences. CyberPay may suspend or terminate Merchant relationships where bribery/corruption concerns arise.