Anti-Bribery & Corruption Policy

Global Gold Verification Platform ("GGVP"), operated by PickNGotech Ltd (UK Company No. 16829327), adopts a zero-tolerance approach to bribery and corruption. This policy applies to all directors, employees, contractors, agents, intermediaries, verified partners and counterparties acting for or on behalf of GGVP, in any jurisdiction.

This policy is designed to comply with, at minimum:

• The UK Bribery Act 2010 (including the corporate offence of failure to prevent bribery, s.7).
• The US Foreign Corrupt Practices Act (FCPA).
• The OECD Convention on Combating Bribery of Foreign Public Officials.
• Local anti-corruption laws of every jurisdiction in which a transaction is performed.

No person acting for or on behalf of GGVP shall, directly or indirectly:

• Offer, promise, give, request, agree to receive or accept any financial or other advantage intended to induce or reward the improper performance of any function or activity.
• Bribe a foreign or domestic public official to obtain or retain business or a business advantage.
• Make facilitation payments — small, unofficial payments to expedite routine government action — regardless of local custom.
• Use third parties, agents or intermediaries to do anything that the company itself could not lawfully do.

Reasonable and proportionate gifts and hospitality given or received in good faith are not prohibited, but must be modest in value, transparent, not influence (or appear to influence) a business decision, and recorded where required. Cash or cash-equivalent gifts are prohibited in all circumstances. Hospitality offered to public officials requires prior written approval from the Compliance Officer.

Bribery and corruption risk is assessed for every counterparty, intermediary and partner during onboarding and reassessed during the engagement. Higher-risk profiles — including those involving public officials, state-owned entities, or jurisdictions ranked low on Transparency International's Corruption Perceptions Index — trigger Enhanced Due Diligence and contractual anti-bribery warranties.

All payments, expenses and contractual arrangements are recorded accurately and in reasonable detail. Off-book accounts, false invoices, inadequately documented payments and unrecorded expenses are strictly prohibited. Internal controls are designed to provide reasonable assurance that no payment is misclassified to obscure a bribe.

Anyone with knowledge or reasonable suspicion of bribery, corruption or any breach of this policy must report it without delay to the Compliance Officer. Reports may be made in confidence. GGVP will not tolerate retaliation of any kind against a person who reports a concern in good faith.

Breach of this policy is a serious matter. For employees and contractors it may result in disciplinary action up to and including termination for cause. For partners and counterparties it may result in immediate termination of the relationship, removal from the platform and referral to law-enforcement authorities. Individuals may also face personal criminal liability under applicable laws.

Overall responsibility for anti-bribery compliance sits with the Compliance Officer, who reports to senior management. Staff and verified partners receive anti-bribery training at onboarding and on a recurring basis. This policy is reviewed at least annually and updated as needed.

To report a concern or request guidance: