Anti-Bribery & Anti-Corruption Policy

This policy applies to all employees, officers, contributors, and any person acting on behalf of OFORO LTD. Breach is grounds for termination and may be referred to law enforcement.

The Act creates four offences relevant to us: section 1 (bribing another); section 2 (being bribed); section 6 (bribing a foreign public official); and section 7 (failure of a commercial organisation to prevent bribery). Section 7 carries strict liability with an "adequate procedures" defence - this policy is part of our defence.

1. Proportionate procedures. This policy, due diligence, and gift/hospitality registers are sized to our risk profile.
2. Top-level commitment. The Board has approved this policy and reviews it annually.
3. Risk assessment. Our highest-risk areas are payments to Indian intermediaries and payments at filming sites - both subject to enhanced due diligence.
4. Due diligence. We check third parties before payment is made, in particular site owners, agents, and intermediaries.
5. Communication and training. All staff and engaged contributors receive a written briefing on this policy at onboarding.
6. Monitoring and review. The DPO maintains the gift register and reports incidents to the Board.

Routine business hospitality and gifts of nominal value are permitted. Anything above £100 per recipient per year must be approved in writing and entered in the register. Gifts to public officials, regardless of value, require prior approval.

Facilitation payments (small unofficial payments to expedite a routine action) are prohibited, including in jurisdictions where they are culturally common. If a facilitation payment is demanded under threat of personal safety, comply if necessary to ensure safety and report immediately to the DPO.

We do not engage agents on a commission basis where the activity could appear to influence a public decision. Indian payment intermediaries are limited to regulated payment service providers (Razorpay, Stripe, Wise) and intermediaries appearing on the RBI's authorised list.

We screen counterparties against UK Sanctions List (Sanctions and Anti-Money Laundering Act 2018), EU consolidated sanctions, and US OFAC SDN. We do not provide Services to sanctioned persons or for sanctioned end-uses.

Suspected breaches must be reported to compliance@nxted.ai or via the Whistleblowing Policy. Retaliation against a person who reports in good faith is itself a breach of this policy.