How We Engage Our Clients and Improve
Our Client Experience

We have developed solid and everlasting relationships as part of our management plan. On all business transactions that occur with clients, partners, or acquisitions, we ensure an efficient communication and relationship. This statement is a core cultural belief and a fundamental element of the success of Nexa DeFi Limited. Members of our community tend to share core values that are highly compatible with those that are central to the business and established at the outset — expertise, integrity and discretion. We treat each other with mutual respect, openness and fairness and are driven by a desire to ‘do the right thing’ by all our stakeholders. This is our culture – it is central to our success. We are therefore proactive in building and reinforcing it.

Anti-Bribery And Corruption Framework

Nexa DeFi Limited operates within the commercial banking laws and protocols. We make sure all business transactions follow our Code of Conduct and values. As a company, we have enforced a robust framework to prevent all forms of bribery and corruption. Our Anti- Bribery and Corruption Policy forbids the actual or attempted use of any form of bribery or corruption, either directly or indirectly, on Nexa DeFi Limited behalf on any business-related activity.

Risk assessment

These include periodic risk assessments to identify and address bribery and corruption risk and controls tailored to manage the risks identified through this process.

Policies & Procedures

Bribery and corruption risks are addressed through a number of other Nexa DeFi Limited policies and procedures, including our Anti-Money Laundering and Counter-Terrorism Financing Policy, incorporating Client Identification. This document is a summary of Nexa DeFi Limited' Anti-Bribery and Corruption Policy and framework. It is not intended to create third party rights or duties or to form part of any contractual agreement between Nexa DeFi Limited and any other party.

Procedures

Nexa DeFi Limited staff must take reasonable steps to avoid, giving or accepting gifts and entertainment that are intended to, or may, improperly influence them or others. We also maintains a Whistle-blower Policy and framework which promotes the escalation and reporting of matters including bribery and corruption. Staff are encouraged to raise matters through line management or to compliance, and can also approach the Integrity Office or anonymously through an externally-hosted staff hotline.

Due Diligence

In dealing with third parties, the Policy requires sufficient due diligence to be undertaken to ensure that they are suitable to be associated with Nexa DeFi Limited, and that appropriate controls are implemented, designed to prevent and detect bribery and corruption. Third parties associated with Nexa DeFi Limited are in turn expected to have appropriate due diligence arrangements and controls in place in relation to the other parties they engage with, on behalf of Nexa DeFi Limited.

Monitoring & Review

Nexa DeFi Limited performs payment monitoring, including monitoring for bribery ‘red flags’ and Nexa DeFi Limited' independent compliance function conducts periodic risk-based monitoring of gifts and entertainment.

Training & Communication

Nexa DeFi Limited promotes staff awareness in compliance with the Anti-Bribery & Corruption framework through the appropriate dissemination of the Policy and procedures (including disciplinary procedures) and training on induction and periodically thereafter