Anti-Bribery and Corruption Policy

Introduction

Aurexus Group Ltd ("Aurexus", "we", "us" or "our") is committed to conducting business with integrity, transparency and in full compliance with the Bribery Act 2010 and all applicable anti-corruption laws.

This Anti-Bribery and Corruption Policy applies to all directors, employees, contractors, agents, consultants and partners acting on behalf of Aurexus anywhere in the world.

Our Commitment

We have a zero-tolerance approach to bribery and corruption. We prohibit:

Offering, promising, giving, requesting, agreeing to receive, or accepting bribes
Facilitation payments — small unofficial payments to speed up routine government actions
Using third parties to channel improper payments
Any activity that could be perceived as corrupt, even if not strictly unlawful in a particular jurisdiction

We compete on the quality of our AI engineering, intelligent transformation capabilities and professional integrity — not through improper inducements.

What Is Bribery?

A bribe is any financial or other advantage offered, promised or given to induce a person to perform their role improperly, or to reward improper performance.

Bribery can involve:

Cash, gifts, hospitality, entertainment or travel
Donations, sponsorships or charitable contributions used as inducements
Employment offers to relatives or associates of decision-makers
Kickbacks, secret commissions or inflated invoices
Improper political or charitable contributions

Both the person giving and the person receiving a bribe may commit an offence under the Bribery Act 2010.

Scope of the Bribery Act 2010

The Act creates four main offences:

Bribing another person (Section 1)
Being bribed (Section 2)
Bribing foreign public officials (Section 6)
Failure of a commercial organisation to prevent bribery (Section 7)

Aurexus maintains adequate procedures to prevent bribery as a defence under Section 7, proportionate to our size and risk profile as a growing technology company.

Permitted Activities

The following are generally permitted when conducted transparently and proportionately:

Normal hospitality that is reasonable, infrequent and directly related to legitimate business promotion (e.g., working lunches, industry events)
Token promotional items of nominal value
Charitable donations made openly through approved channels without expectation of improper advantage
Fees paid to legitimate advisers and agents under transparent, documented agreements

All hospitality and gifts above defined thresholds must be pre-approved and recorded.

Prohibited Activities

You must not:

Offer or accept gifts, hospitality or payments that could influence a business decision
Make facilitation payments of any kind
Use agents, distributors or intermediaries without due diligence and written agreements
Make political donations on behalf of Aurexus without board approval
Create off-book accounts or false invoices
Ignore or conceal suspected bribery

Third Parties

We conduct proportionate due diligence on agents, partners, subcontractors and intermediaries who interact with public officials or commercial decision-makers on our behalf. Contracts require compliance with anti-bribery laws and audit rights where appropriate.

This is particularly relevant in healthcare, pharmaceutical and public sector engagements where BioAegix, NPTTE PharmaNG and our consulting services operate.

Public Officials

Special care is required when dealing with government officials, NHS organisations, regulatory bodies and international public officials. No payment or advantage may be offered to obtain or retain business or secure improper performance of a public function.

Record Keeping

All financial transactions must be accurately recorded. We maintain books, accounts and records that fairly reflect all transactions. False, incomplete or misleading records are prohibited.

Reporting and Whistleblowing

If you suspect or witness bribery or corruption — involving Aurexus personnel, clients, suppliers or partners — report it promptly:

Email: admin@aurexus-group.com
Subject line: Anti-Bribery Report

Reports are treated confidentially to the extent possible. We do not tolerate retaliation against good-faith reporters.

See our Complaints Procedure for additional channels.

Consequences

Violations of this policy may result in:

Disciplinary action, up to and including termination of employment or contract
Reporting to law enforcement authorities
Civil and criminal penalties under the Bribery Act 2010, including unlimited fines and imprisonment for individuals

Aurexus may also be liable for failing to prevent bribery by associated persons.

Training and Communication

All personnel are made aware of this policy during onboarding. Refresher awareness is provided as the team grows and when entering higher-risk markets or engagements.

Governance

Leadership is responsible for ensuring adequate procedures are maintained. This policy is reviewed at least annually.

Due Diligence Summary

Our adequate procedures include:

This written policy
Risk assessment proportionate to our operations
Due diligence on relevant third parties
Communication and training
Monitoring, reporting and review

As an early-stage company, we implement these procedures proportionately and will strengthen them as our commercial activity and geographic reach expand.

Contact

Email: admin@aurexus-group.com
Post: Aurexus Group Ltd, Unit A, 82 James Carter Road, Mildenhall, Bury St. Edmunds, Suffolk, England, IP28 7DE

Governing law: England and Wales