Anti-Bribery & corruption.

1. Statement of policy

MTX Finance Ltd. is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships. MTX has a zero-tolerance approach to bribery and corruption.

2. Scope

This Policy applies to all directors, officers, employees, contractors, agents, and any third party acting for or on behalf of MTX Finance Ltd., whether located in Canada or in any other jurisdiction.

3. Definitions

• Bribery — offering, promising, giving, requesting, agreeing to receive, or accepting anything of value as an inducement or reward for action that is illegal, unethical, or a breach of trust.
• Corruption — abuse of entrusted power for private gain, including but not limited to bribery, kickbacks, embezzlement, fraud, and influence peddling.
• Facilitation payment — small payment made to a foreign public official to expedite a routine government action. Prohibited under this Policy regardless of local custom.

4. Applicable legislation

• Corruption of Foreign Public Officials Act (CFPOA) — Canada.
• Criminal Code of Canada — bribery and corruption offences.
• UK Bribery Act 2010 — given MTX's UK provider (Cublox) and UK client exposure.
• US Foreign Corrupt Practices Act (FCPA) — given OFAC-screening counterparty exposure.

5. Prohibitions

MTX representatives must not directly or indirectly:

• Offer, promise, give, request, agree to receive, or accept a bribe.
• Make or accept a facilitation payment.
• Use MTX's funds, services, or platforms to facilitate or conceal bribery or corruption.
• Engage with any third party where there is reasonable cause to suspect involvement in bribery or corruption without escalation to the Compliance Officer.

6. Gifts, hospitality, and entertainment

Gifts and hospitality of modest value are permitted where they are: lawful, proportionate, openly given, properly recorded, and not intended to influence a business decision. Gifts of cash or cash equivalents are prohibited. Gifts to or from public officials require Compliance Officer pre-approval.

7. Donations and sponsorships

Political donations on behalf of MTX are prohibited. Charitable donations and sponsorships are subject to written Compliance Officer pre-approval and recorded in the firm's donation register.

8. Third-party due diligence

MTX conducts risk-based due diligence on counterparties, providers, and intermediaries. Adverse-media screening (via SumSub) is part of onboarding and ongoing monitoring. Any indicator of bribery or corruption history triggers escalation to the Compliance Officer.

9. Books and records

All payments and transactions by or on behalf of MTX must be accurately and transparently recorded. False, misleading, or off-the-record entries are prohibited.

10. Reporting suspected bribery or corruption

Any director, officer, employee, contractor, or agent who suspects bribery or corruption involving MTX must report it immediately to the Compliance Officer at compliance@mtxfinance.com. MTX prohibits retaliation against any person who reports a concern in good faith. Anonymous reports are accepted and investigated to the extent possible.

11. Training and awareness

All staff receive anti-bribery and corruption training as part of the foundation AML training module. Refreshers are delivered annually.

12. Consequences of non-compliance

Breach of this Policy is grounds for disciplinary action up to and including termination of employment or engagement. Where conduct may amount to a criminal offence under applicable law, MTX co-operates with law-enforcement authorities.

13. Review

This Policy is reviewed at least annually.