Anti-Bribery & Corruption Policy

1.1 No person acting for or on behalf of ERIANUX, LLC (the “Company”) may offer, promise, give, authorise, solicit, agree to receive or accept Anything of Value where the purpose or effect is to induce or reward the improper performance of any function or activity, or to obtain or retain business or an improper business advantage.

1.2 The prohibition applies irrespective of (a) the value involved, (b) local custom or market practice, (c) whether a competitor is believed to behave otherwise, (d) whether the Company would lose the opportunity by refusing, and (e) whether the benefit flows to the individual or to the Company.

1.3 Commercial pressure, deadline pressure and the prospect of lost revenue are expressly not mitigating circumstances under this policy.

2.1 Entity. The Company is a Wyoming limited liability company organised under W.S. 17-29-101 et seq. It has no subsidiaries and no joint ventures; where it engages agents or contractors, this Policy binds them by contract.

2.2 Persons bound. The Managing Member; any employee, officer or intern; any contractor, consultant, agency, reseller or fulfilment partner; and every affiliate acting under the Affiliate Program Terms. Persons in the latter two groups are Associated Persons for the purposes of s.8 of the UK Bribery Act 2010, and the Company may be liable for their conduct.

2.3 Territorial reach. The Company sells into the United States, the United Kingdom, the European Union, Canada and other markets. It therefore treats itself as within the reach of both the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010, and applies the stricter of the two throughout.

• Foreign Corrupt Practices Act of 1977, 15 U.S.C. §§78dd-1 to 78dd-3 — prohibits corrupt payments to foreign officials and, through its accounting provisions, requires accurate books and records and adequate internal accounting controls.
• UK Bribery Act 2010 — s.1 (bribing another person), s.2 (being bribed), s.6 (bribery of a foreign public official) and s.7 (failure of a commercial organisation to prevent bribery). The s.7 corporate offence carries an unlimited fine and admits one defence: that the organisation had adequate procedures in place. This policy, together with the controls at clauses 6 to 11 and the records at clause 13, is the Company’s adequate-procedures evidence.
• Economic Crime and Corporate Transparency Act 2023, s.199 — the UK corporate offence of failure to prevent fraud, in force from 1 September 2025, with a defence of reasonable fraud-prevention procedures. The Company applies the same control set to fraud risk, as recorded in the Fraud Advisory Notice.
• Other instruments — the OECD Convention on Combating Bribery of Foreign Public Officials; Canada’s Corruption of Foreign Public Officials Act; the commercial-bribery provisions of Texas Penal Code §32.43; and the anti-kickback and unfair-practice provisions applicable in other markets into which the Company sells.

“Anything of Value” — any payment, cash equivalent, gift card, gift, meal, travel, accommodation, entertainment, loan, discount, free or discounted licence, sponsorship, internship or employment offer, charitable or political contribution, or other benefit, whether direct or indirect, and whether or not it carries a cash value. “Public Official” — any officer or employee of a government, agency, state-owned or state-controlled enterprise, public international organisation, political party or candidate, and any person acting in an official capacity for any of them. “Facilitation Payment” — a payment, however small, to secure or expedite a routine governmental action to which the payer is already entitled. “Kickback” — the return of a portion of a payment, commission or discount as consideration for awarding or retaining business.

5.1 Method. Risk is assessed against the vectors identified in Ministry of Justice guidance: country, sector, transaction, business-opportunity and business-partnership risk. The assessment is recorded, dated and revisited on each review or material change.

5.2 Current assessment. The Company sells standardised software licences and subscriptions directly to individual traders through Stripe and PayPal, and merchandise through third-party print and fulfilment partners. It holds no government contract, tenders for no public work, employs no sales intermediary or agent paid on the outcome of a negotiation, and requires no licence or permit from a foreign authority to trade. The assessed inherent bribery risk is accordingly low.

5.3 Residual risk areas. Three areas carry more than nominal risk and are controlled specifically: (a) the Affiliate Program, where a commission-driven third party speaks for the Company; (b) commercial bribery in the supply chain, where merchandise, print and dropship partners are engaged in jurisdictions with higher corruption indices; and (c) inducements offered to the Company — a payment, free service or revenue share offered by a broker, prop firm, platform vendor or reviewer in exchange for a recommendation, a ranking or an integration.

5.4 Proportionality. The Company adopts this policy notwithstanding its low assessed risk. Absence of past incident is not a control, and the policy is a routine and reasonable item for a bank, processor, platform or enterprise customer to request on file.

6.1 Principle. A modest, occasional and openly given gift or meal in the ordinary course of a business relationship is not prohibited. Anything offered, given or received with the intent — or the reasonable appearance — of influencing a decision is prohibited irrespective of value.

6.2 Tests. Any gift or hospitality must satisfy all of: lawful in both jurisdictions; proportionate and infrequent; given openly and capable of being recorded; unconnected to a pending decision, negotiation or dispute; not cash or a cash equivalent; and not embarrassing to the Company if published.

6.3 Thresholds. Prior written approval from the Managing Member is required for any single gift or hospitality item given or received with a value above US$100, and for any aggregate exceeding US$250 to or from the same counterparty in any twelve-month period. These are Company-set control thresholds, not legal safe harbours.

6.4 Absolute prohibitions. Cash, gift cards, cryptocurrency, personal loans, and anything of value to a Public Official or a member of a Public Official’s family, in any amount, without prior written approval.

6.5 Register. Approvals and declarations are recorded in the gifts and hospitality register held with the Company’s compliance records. A gift that could not be declined without causing offence must be declared and, where practicable, donated or surrendered to the Company.

7.1 Facilitation Payments are prohibited. The Company will accept delay, administrative inconvenience and commercial loss in preference to making one.

7.2 Duress exception. The single exception is a payment made where there is an imminent threat to the life, limb or liberty of any person. Such a payment is not a breach of this policy, but must be reported to legal@erianux.com at the earliest safe opportunity and recorded accurately in the Company’s books for what it was.

8.1 Affiliate commission. Commission is payable only on a verifiable referred sale, at a published rate, to a named and verified payee, recorded against the underlying order. Commission may not be paid to a person who is in a position to influence a purchasing decision on behalf of a third-party organisation without that organisation’s knowledge, and may not be split, rebated or redirected to a third party.

8.2 Inbound inducements. Any offer of payment, revenue share, free service or benefit in exchange for a recommendation, ranking, integration or endorsement must be declined or disclosed. Where a paid relationship exists and a recommendation is nonetheless made, the material connection is disclosed in accordance with the FTC Endorsement Guides, 16 C.F.R. Part 255.

8.3 Charitable and political contributions. The Company makes no political contribution of any kind. Charitable donations require prior written approval, may not be made at the request or suggestion of a counterparty seeking a commercial decision, and are recorded by recipient and amount.

9.1 Risk-based diligence. Before engaging a supplier, fulfilment partner, reseller or agency, the Company establishes who the counterparty is, who ultimately owns or controls it, whether it or its principals appear on a sanctions or debarment list, and whether its pricing and payment arrangements are commercially explicable. The depth of enquiry is proportionate to the value and the country risk of the engagement.

9.2 Affiliate onboarding. Affiliate applications are reviewed before approval. Applications are refused, and existing accounts closed, where the applicant promotes guaranteed returns, operates undisclosed paid placements, or cannot be identified to a verified payout method.

9.3 Contractual terms. New and renewed supplier and partner agreements include, as a minimum: compliance with applicable anti-bribery law; a prohibition on Facilitation Payments; a right of termination for breach; a prohibition on unapproved subcontracting; and an obligation to notify the Company of any bribery allegation touching the engagement.

9.4 Payments. Payments are made to the contracting entity, in the country of the contract or performance, to a bank account in the counterparty’s own name, against an invoice that identifies the goods or services. Payments to a third party, to an unrelated jurisdiction, or in cash are prohibited.

Consistent with the accounting provisions of the FCPA, all transactions are recorded accurately and in reasonable detail. No entry may be false, incomplete or mischaracterised; no fund or account may be maintained off the Company’s books; and expense claims must identify the recipient and business purpose of any hospitality. Payment processing runs through Stripe and PayPal rather than manual transfers, which produces an independent transaction record the Company cannot unilaterally alter — a structural control the Company relies on and does not circumvent.

11.1 Communication. This policy is published openly at erianux.com and is incorporated by reference into the Affiliate Program Terms and into supplier agreements.

11.2 Training. The Company has no employees at the date of this version. Any employee or contractor engaged in a role touching supplier selection, payments or marketing will be briefed on this policy before assuming the role and will acknowledge it in writing; the briefing is recorded. Affiliates receive the prohibitions in summary form at onboarding.

11.3 Reporting. Suspected bribery, an attempted inducement, or a request for a Facilitation Payment must be reported to legal@erianux.com promptly. Reports are handled under clause 13 of the Code of Conduct, with external review where the Report concerns the Managing Member. Good-faith reporting is protected; retaliation is a separate and serious breach.

Breach is treated as gross misconduct or as material breach of contract, as applicable, and may result in termination, forfeiture of unpaid commission, recovery of loss, and referral to law enforcement. Individuals should understand that bribery is a criminal offence in its own right: under the UK Bribery Act 2010 an individual faces up to ten years’ imprisonment and an unlimited fine, and under the FCPA individual criminal liability attaches independently of any corporate resolution.

13.1 Records. The Company retains the dated risk assessment, the gifts and hospitality register, conflict disclosures, third-party due-diligence files, training acknowledgements, reports and their outcomes, and the approval record for each policy version.

13.2 Retention. Not less than five years from the end of the relationship or closure of the matter.

13.3 Review. Annually, and on the engagement of a first employee, the appointment of any sales agent or reseller, entry into a government or enterprise contract, entry into a new higher-risk jurisdiction, or any reported incident. Each review is logged whether or not the text changes.

Where this policy requires approval, approval means a written decision from the Managing Member, recorded before the event rather than reconstructed afterwards.

15.1 Why it belongs here. In the retail trading-tools market, the realistic corruption risk is not a payment to a government official. It is the quiet purchase of a recommendation: a payment, a free licence, a revenue share or a lead-generation fee that buys a favourable review, a ranking, a course mention or a platform integration without the audience being told.

15.2 Outbound. The Company may pay for advertising, and may pay commission through its published affiliate programme. It does not pay for a review, a comparison-table position, a “best indicator” placement, or an undisclosed mention presented as independent opinion. Where the Company provides a free or discounted licence for review, it is provided on the express condition that the recipient discloses it, and the Company does not ask for editorial control in exchange.

15.3 Inbound. The Company does not accept payment, revenue share, rebate or free service from a broker, prop firm, data vendor or platform in exchange for recommending them, steering customers to them, or integrating with them in preference to a better alternative. Where a commercial relationship exists and a recommendation is nevertheless appropriate, it is disclosed.

15.4 Affiliate integrity. Commission is not a bribe, but an undisclosed commission presented as a personal recommendation is a deception, and paying for one makes the Company a party to it. Disclosure obligations under the FTC Endorsement Guides are therefore enforced as an anti-corruption control as well as an advertising one.

16.1 On receipt. A report is logged with the date received, the substance of the allegation and the person handling it. Where the report implicates the Managing Member, external counsel or an external accountant is instructed before any step is taken.

16.2 Preservation. Relevant records — correspondence, invoices, processor records, contracts, expense claims — are preserved as soon as an allegation is received. No record is deleted, and no routine deletion schedule is allowed to run over material within scope.

16.3 Enquiry. The Company establishes what payment or benefit is alleged, who authorised it, what record exists, and whether a transaction was affected. Suspect payments and relationships are suspended while the enquiry runs.

16.4 Outcome. Findings are recorded in writing with the evidence relied on. Where conduct is substantiated, the Company terminates the relationship, corrects its books, considers self-reporting to the appropriate authority on legal advice, and remediates the control that failed.

16.5 Cooperation. The Company cooperates with an authority’s enquiry and does not use a settlement, severance or confidentiality term to discourage a person from speaking to a regulator or prosecutor.

The six principles of the UK Ministry of Justice guidance under s.9 of the Bribery Act 2010, mapped to this policy.

Any of the following requires escalation to legal@erianux.com before the transaction proceeds: a counterparty that asks for payment to a third party, an offshore account or in cash; a commission or discount that is unexplained by the work done; a request for an invoice that misdescribes the service; a partner who says a payment is “how things are done here”; a counterparty who refuses to accept anti-bribery contract terms; a relative or associate of a Public Official introduced as a necessary intermediary; a request for a gift, licence or trip during a live negotiation; an offer of payment for a favourable review, ranking or integration; and any pressure to close before diligence is complete.