Introduction
Leet Capital is committed to maintaining the highest standards of ethical conduct, integrity, transparency, and compliance with all applicable laws and regulations, including the MACC Act 2009. This document outlines the policies and procedures for Anti-Bribery and Whistleblowing within our organization.

Bribery and corruption in any form are strictly prohibited. This policy is designed to prevent bribery and corruption, promote ethical business practices, and encourage the reporting of any wrongdoing or unethical behavior.

Scope
This policy applies to all employees, directors, officers, shareholders, contractors, consultants, agents, intermediaries, and any other third party representing or acting on behalf of Leet Capital.

Anti-Bribery Policy
Definition of Bribery
Bribery is the act of offering, giving, promising, or accepting any undue advantage to influence a decision or action. This includes financial or non-financial benefits, such as gifts, hospitality, entertainment, or employment.

Prohibited Activities
The following activities are strictly prohibited:

• Offering, giving, promising, or accepting bribes in any form.
• Offering or accepting items of value in a business context that are not reasonable, proportionate, and transparent, or in compliance with applicable laws and regulations.
• Engaging in any activity that could be construed as bribery, corruption, or unethical conduct.
• Facilitating, participating in, or condoning any bribery scheme or corrupt practice.
• Failing to report any suspicion, knowledge, or evidence of bribery, corruption, or unethical behavior.

Key Principles
The following are the key principles:

• Zero Tolerance: The company has a zero-tolerance approach to bribery and corruption.
• Prohibition of Facilitation Payments: Facilitation payments are strictly prohibited.
• Transparency: All business dealings must be transparent and properly recorded.
• Accountability: Employees and third parties must adhere to this policy and report any violations.

Due Diligence
Employees must exercise due diligence when dealing with third parties to ensure that they are not involved in any bribery or corruption. This includes conducting background checks, verifying credentials, and monitoring relationships.

Whistleblowing Policy
Definition of Whistleblowing
Whistleblowing is the act of reporting any wrongdoing or unethical behavior within Leet Capital. This includes bribery, corruption, fraud, theft, discrimination, harassment, or any other illegal or unethical activity.

Protected Disclosures
Employees are encouraged to report any wrongdoing or unethical behavior without fear of retaliation. All disclosures made in good faith will be protected, and the identity of the whistleblower will be kept confidential to the extent possible.

Reporting Channels
Employees can report any wrongdoing or unethical behavior through the following channels:

• Directly to their supervisor or manager.
• To the Human Resources department.
• To the Compliance Officer.
• Through an anonymous hotline or online reporting system.

Investigation and Action
All reports of wrongdoing or unethical behavior will be investigated promptly and thoroughly. Appropriate action will be taken against any employee found to have engaged in wrongdoing or unethical behavior.

Consequences of Non-Compliance
Any employee found to have violated this policy will be subject to disciplinary action, up to and including termination of employment. Leet Capital may also take legal action against any employee or third party involved in bribery or corruption.

Training and Awareness
Leet Capital will provide regular training and awareness programs to educate employees about this policy and their responsibilities.

Conclusion
This policy is designed to promote a culture of ethical conduct and integrity within Leet Capital. We encourage all employees to report any wrongdoing or unethical behavior without fear of retaliation. By working together, we can create a workplace where everyone feels safe and respected.