Anti-Corruption Policy

1. Purpose and Scope

1.1 Purpose

It is the policy of Aviluxe Aviation LLC d/b/a Jetaxia and its affiliates and controlled subsidiaries (the "Company" or "Jetaxia") to conduct all of its operations and activities in complete compliance with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA"), the UK Bribery Act 2010 (where applicable), and other applicable anti-corruption and anti-bribery laws (collectively, the "anti-corruption laws").

The Company strictly prohibits giving, promising, offering, receiving, or requesting, directly or indirectly, anything of value for the purpose of gaining a commercial advantage, securing any improper benefit, or influencing the performance of any official function. This Anti-Corruption Policy (this "Policy") explains how this prohibition is applied and enforced.

1.2 Scope

This Policy applies to:

(a) the Company, its affiliates, divisions, and controlled subsidiaries;
(b) all directors, officers, and employees of the Company; and
(c) all agents, contractors, consultants, Vendors, Trip Support Partners, joint venture partners, and other persons acting for or on behalf of the Company.

Failure to comply with this Policy may result in sanctions and disciplinary action, including termination of employment, termination of the Vendor or partner relationship, forfeiture of payments, and referral to law enforcement.

2. Overview of the FCPA

The FCPA is a U.S. federal law that prohibits bribery of foreign officials by U.S. businesses and imposes related books and records and internal controls requirements. The FCPA has two primary components:

(a) an anti-bribery provision that prohibits offering, promising, or giving anything of value to foreign government officials (including candidates and political party officials) in order to obtain or retain business, to have business directed, or to gain "any improper advantage"; and
(b) accounting and record-keeping provisions intended to prevent the failure to properly record transactions and the falsification of records to conceal improper conduct.

To the extent Jetaxia's activities involve foreign officials, foreign governments, or foreign business, the Company will comply fully with these requirements. The UK Bribery Act imposes similar and in some respects broader prohibitions, including on private-to-private bribery, and applies where the Company or its agents have a UK nexus.

3. Definition of "Government Official"

As used in this Policy, the term "government official" includes:

(a) any officer or employee of any national, state, provincial, local, or municipal government, or any department, agency, or instrumentality of any such government;
(b) any officer or employee of a state-owned or state-controlled entity, including certain airport authorities, aviation authorities, state-owned airlines, state-owned aircraft operators, and similar entities;
(c) any person acting in an official capacity for or on behalf of any government or state-owned entity;
(d) any candidate for political office;
(e) any political party or official thereof;
(f) any officer or employee of a public international organization (for example, the International Civil Aviation Organization);
(g) any person holding a legislative, administrative, or judicial position in any foreign state; and
(h) for purposes of the Company's U.S. operations, any U.S. federal, state, or local government employee, airport or aviation authority employee, or regulator.

4. Accounting and Record-Keeping

The Company and all persons subject to this Policy shall maintain books and records that accurately and fairly reflect all transactions and conform to all applicable legal and accounting standards.

No person working for or on behalf of the Company may:

(a) make any false, misleading, or inaccurate entry in the Company's books and records;
(b) participate in the creation of any false or misleading document supporting the disbursement or receipt of Company funds or other assets;
(c) establish or maintain any undisclosed or unrecorded fund, account, or asset for any purpose;
(d) use personal funds or off-the-books accounts to make payments on behalf of the Company that would be improper if made directly by the Company; or
(e) fail to record, or record improperly, any transaction involving the Company.

The Company's accounting controls are designed to ensure that:

(a) transactions are executed with management's authorization;
(b) transactions are recorded in a manner sufficient to permit preparation of financial statements in conformity with generally accepted accounting principles and to maintain accountability for assets;
(c) access to assets is permitted only with management's authorization; and
(d) recorded assets are compared to actual assets at reasonable intervals, with appropriate action taken as to any differences.

Any person who becomes aware of an unrecorded or improperly recorded fund, asset, or transaction shall promptly report the matter under Section 16 below.

5. General Prohibition on Bribery

No person working for or on behalf of the Company, regardless of nationality or location, may directly or indirectly give, promise, authorize, offer, accept, or request any monetary payment or anything of value that is intended to:

(a) induce the recipient to take or refrain from taking official or business action;
(b) secure an improper advantage;
(c) improperly influence a business decision; or
(d) reward past improper conduct.

This prohibition applies to dealings with government officials and private parties, including Customers, Vendors, Trip Support Partners, FBOs, and other business counterparties on the Platform.

"Anything of value" is broadly interpreted and includes cash and cash equivalents, gifts, meals, entertainment, travel, lodging, employment or business opportunities for relatives or associates, charitable or political contributions made at the recipient's request, discounts, loans on preferential terms, and any other direct or indirect benefit.

6. Direct Payments to Government Officials

No person working for or on behalf of the Company may offer, pay, give, promise, or authorize the payment of any money or anything of value to, or for the benefit of, any government official for the purpose of influencing the performance of official functions, obtaining or retaining business, directing business, or gaining a commercial advantage.

7. Indirect Payments and Intermediaries

No person working for or on behalf of the Company may offer, pay, give, promise, or authorize the payment of any money or anything of value to any third party (including an agent, consultant, Vendor, or partner) while being aware of a high probability that the third party has offered, given, or will offer or give money or anything of value to or for the benefit of any government official for an improper purpose.

Persons subject to this Policy may be considered "aware of a high probability" where circumstances raise reasonable suspicion that improper payments are likely, even in the absence of specific knowledge. Willful blindness is not a defense.

8. Gifts to Government Officials

Gifts to government officials are prohibited unless:

(a) specifically permitted by applicable written law;
(b) modest in value (typically under $50 USD);
(c) customary under local business practice;
(d) not cash or cash equivalent; and
(e) pre-approved in writing by the Company's Executive Management.

Requests to provide gifts to government officials must be submitted to Executive Management at support@jetaxia.com with "Anti-Corruption Approval Request" in the subject line.

9. Entertainment of Government Officials

Entertainment of government officials, including meals, events, and travel, is prohibited unless:

(a) specifically permitted by applicable written law;
(b) reasonable in nature and value;
(c) directly related to a bona fide business purpose (for example, a demonstration or business meeting);
(d) attended by Company personnel; and
(e) pre-approved in writing by Executive Management.

10. Travel and Lodging for Government Officials

The Company may pay reasonable and bona fide travel and lodging expenses for government officials where:

(a) the expenses are consistent with applicable law;
(b) the expenses are directly related to the promotion, demonstration, or explanation of the Company's products or services, or to the execution or performance of a contract with the government or agency employing the official;
(c) the travel schedule is tightly controlled to reflect the bona fide business purpose (no side trips, entertainment, or expenses for family members);
(d) payments are made to vendors directly (not to the official personally) where feasible; and
(e) Executive Management has approved the expenses in writing in advance.

11. Meals for Government Officials

The Company may pay or reimburse reasonable dining expenses for government officials in conjunction with approved travel under Section 10, or as part of a bona fide business meeting. Such expenses must be:

(a) modest and appropriate to the business purpose;
(b) attended by Company personnel;
(c) properly documented (purpose, attendees, amount); and
(d) pre-approved in writing by Executive Management or conform with written guidelines established by Executive Management.

12. Facilitation Payments

A "facilitation payment" is a small payment made to a government official to expedite or secure the performance of a routine, non-discretionary governmental action that the official is otherwise obligated to perform (for example, expediting routine inspections or permit issuance).

No person working for or on behalf of the Company may make facilitation payments unless:

(a) the payment is expressly permitted by applicable written law (for example, a published fast-track service fee paid to the governmental authority, not to the individual); and
(b) the payment is pre-approved in writing by Executive Management.

Under most anti-corruption laws outside the United States (including the UK Bribery Act), facilitation payments are prohibited outright. When in doubt, do not pay, and contact Executive Management.

13. Agents, Consultants, Vendors, and Third Parties

The Company is responsible under anti-corruption laws for the actions of third parties acting on its behalf. Accordingly:

(a) every agreement with an agent, consultant, professional advisor, Vendor, Trip Support Partner, joint venture partner, or other third party acting on behalf of the Company shall contain a certification that the third party agrees to comply with this Policy and applicable anti-corruption laws;
(b) such third parties shall re-certify compliance on at least an annual basis where the relationship is ongoing and material;
(c) reasonable due diligence shall be conducted on the reputation, background, and compliance history of third parties before engagement, and on an ongoing basis where warranted;
(d) payments to third parties shall be consistent with the services provided, properly documented, and made to verifiable bank accounts in the third party's name (no cash, no payments to numbered accounts, no payments to third-party intermediaries not identified in the contract); and
(e) red flags (for example, unusual payment requests, requests for secrecy, excessive compensation, lack of transparent ownership, or known corruption in the country of operation) shall be escalated to Executive Management for review before engagement or payment.

14. Political and Charitable Contributions

Company personnel shall comply strictly with all applicable laws governing political and charitable contributions. Unless expressly permitted by law and pre-approved in writing by Executive Management:

(a) no political contribution of any kind, whether federal, state, or local, may be made on behalf of the Company or using Company funds;
(b) no charitable contribution may be made at the request of a government official, or in circumstances where it could appear to be a substitute for a prohibited payment; and
(c) personal political or charitable contributions by employees, made with personal funds and not in their capacity as Company representatives, are not restricted by this Policy, but must not be attributed to or reimbursed by the Company.

15. Training and Certification

The Company may require personnel, agents, Vendors, Trip Support Partners, and other third parties to:

(a) complete Anti-Corruption Training on an annual or other periodic basis;
(b) sign annual certifications of compliance with this Policy and applicable anti-corruption laws; and
(c) maintain training records for audit and verification.

The Company shall provide or arrange such training and certifications.

16. Reporting Violations

Any person subject to this Policy who becomes aware of an actual or suspected violation of this Policy, applicable anti-corruption laws, or the Company's accounting and record-keeping requirements shall report the matter promptly to:

Email: support@jetaxia.com (subject line: "Anti-Corruption Report")

Phone: (682) 900-5811

Reports may be made anonymously. Jetaxia will investigate reports in good faith and confidentially to the extent consistent with a thorough investigation and applicable law.

Non-Retaliation. Jetaxia prohibits retaliation against any person who reports a suspected violation in good faith, who participates in an investigation, or who refuses to participate in conduct that would violate this Policy. Retaliation is itself a violation subject to disciplinary action, up to and including termination. Knowingly false reports are also violations.

17. Consequences of Violation

Violations of this Policy may result in:

(a) disciplinary action including termination of employment;
(b) termination of the Vendor, partner, or third-party relationship;
(c) forfeiture of pending payments and clawback of prior payments;
(d) civil and criminal referral to appropriate authorities;
(e) civil claims by the Company for damages, indemnification, or injunctive relief; and
(f) any other remedy available under applicable law or contract.

Violations of anti-corruption laws can also result in substantial personal liability (including imprisonment and fines) for the individuals involved, as well as substantial corporate liability for the Company.

18. Records and Documentation

The Company shall maintain records of:

(a) all approvals granted under this Policy (for example, for gifts, entertainment, travel, and facilitation payments);
(b) due diligence performed on third parties;
(c) training records and certifications; and
(d) reports and investigations.

These records shall be retained for at least seven (7) years or such longer period as required by applicable law.

19. Updates to This Policy

The Company may update this Policy from time to time. Updates will be posted and communicated to relevant personnel, Vendors, and partners. Continued engagement with the Company after the effective date of an updated Policy constitutes acceptance.

20. Questions and Contact

Questions about this Policy, its application to specific facts, or requests for approvals under Sections 8 through 14 should be directed to:

Aviluxe Aviation LLC d/b/a Jetaxia

4115 Wild Azalea Ave

Fort Worth, TX 76116

Email: support@jetaxia.com (subject line: "Anti-Corruption Approval Request" or "Anti-Corruption Question")

Phone: (682) 900-5811