Anti-Bribery and Corruption

Anti-Bribery and Corruption

Date: 25 October 2025

Version: 1.0

Commitment to Integrity and Ethical Conduct

At Nova Digital FZE (“Nova Digital”), integrity, fairness, and transparency form the foundation of our business practices. We recognise that preserving the trust and confidence of our clients, investors, employees, and partners is fundamental to our success as a regulated investment manager.

Nova Digital maintains a zero-tolerance approach to bribery, corruption, or any form of unethical conduct. Our Anti-Bribery and Corruption Policy establishes clear standards and controls designed to prevent, detect, and address improper behaviour across all areas of our operations.

Our Standards

All employees, officers, directors, and representatives of Nova Digital are required to act with the highest level of honesty and professionalism in all dealings, whether internal or external. The same ethical expectations extend to third-party service providers, agents, and business partners acting on our behalf.

No individual may, directly or indirectly, offer, promise, solicit, or accept any payment, gift, or advantage intended to improperly influence a business decision or secure an unfair benefit. Any form of facilitation payment, kickback, or improper inducement is strictly prohibited.

Governance and Reporting Obligations

Nova Digital’s governance framework provides oversight of anti-bribery and corruption controls through regular monitoring, employee training, and independent compliance review.

Any suspected or actual breach of this policy must be reported immediately to the Compliance Officer for investigation. Confirmed instances of non-compliance may lead to disciplinary action, up to and including termination of employment or contract, and, where appropriate, notification to the Virtual Assets Regulatory Authority (VARA) or other competent authorities.

Our Commitment

Nova Digital remains unwavering in its commitment to ethical conduct, responsible governance, and compliance with all applicable laws and regulations. We will continue to foster a corporate culture that rejects bribery and corruption in all forms and upholds the trust placed in us by our clients and stakeholders.

Date: 25 October 2025

Version: 1.0

Commitment to Integrity and Ethical Conduct

At Nova Digital FZE (“Nova Digital”), integrity, fairness, and transparency form the foundation of our business practices. We recognise that preserving the trust and confidence of our clients, investors, employees, and partners is fundamental to our success as a regulated investment manager.

Nova Digital maintains a zero-tolerance approach to bribery, corruption, or any form of unethical conduct. Our Anti-Bribery and Corruption Policy establishes clear standards and controls designed to prevent, detect, and address improper behaviour across all areas of our operations.

Our Standards

All employees, officers, directors, and representatives of Nova Digital are required to act with the highest level of honesty and professionalism in all dealings, whether internal or external. The same ethical expectations extend to third-party service providers, agents, and business partners acting on our behalf.

No individual may, directly or indirectly, offer, promise, solicit, or accept any payment, gift, or advantage intended to improperly influence a business decision or secure an unfair benefit. Any form of facilitation payment, kickback, or improper inducement is strictly prohibited.

Governance and Reporting Obligations

Nova Digital’s governance framework provides oversight of anti-bribery and corruption controls through regular monitoring, employee training, and independent compliance review.

Any suspected or actual breach of this policy must be reported immediately to the Compliance Officer for investigation. Confirmed instances of non-compliance may lead to disciplinary action, up to and including termination of employment or contract, and, where appropriate, notification to the Virtual Assets Regulatory Authority (VARA) or other competent authorities.

Our Commitment

Nova Digital remains unwavering in its commitment to ethical conduct, responsible governance, and compliance with all applicable laws and regulations. We will continue to foster a corporate culture that rejects bribery and corruption in all forms and upholds the trust placed in us by our clients and stakeholders.