Effective Date: December 2025
Last Updated: December 2025

XONIK (“XONIK,” “we,” “our,” or “us”) is committed to conducting its business with integrity, transparency, and accountability, in compliance with applicable laws, regulations, and ethical standards across all jurisdictions in which it operates.

This Compliance & Ethics page describes XONIK’s approach to governance, legal compliance, risk management, and ethical conduct. It is intended to provide clarity on how compliance is embedded into our operations and decision-making, while appropriately reflecting the scope and nature of our business.

Our Compliance Philosophy

Compliance at XONIK is a foundational business principle, not a formality.

We are committed to:

• Operating lawfully, ethically, and responsibly
• Upholding high standards of professional conduct
• Managing risk in a proportionate and practical manner
• Acting with fairness, transparency, and accountability

Compliance considerations are integrated into XONIK’s governance framework and day-to-day operations, rather than treated as a standalone function.

Scope and Applicability

XONIK’s compliance framework applies, as relevant, to:

• Employees, contractors, and representatives acting on our behalf
• Business partners, suppliers, and service providers, where applicable
• Advisory, technology, commercial, and operational activities
• Website usage and business communications

Compliance obligations are assessed and applied based on the nature of the activity, the jurisdiction involved, and the associated risk profile.

Legal and Regulatory Compliance

XONIK seeks to comply with applicable laws and regulations relevant to its operations, which may include, where applicable:

• Data protection and privacy requirements
• Anti-bribery, anti-corruption, and integrity laws
• Trade sanctions and export control regimes
• Employment, labor, and human rights standards
• Competition and fair-dealing obligations

Legal requirements vary across jurisdictions. XONIK’s compliance efforts are designed to align with applicable obligations to the extent they apply and in a manner proportionate to business activities.

Data Protection and Information Security

Protecting information assets and personal data is a core component of XONIK’s compliance approach.

Our practices include:

• Processing personal information in accordance with our Privacy Policy
• Implementing reasonable administrative, technical, and organizational safeguards
• Limiting access to information on a need-to-know basis
• Managing data in accordance with legal, contractual, and operational requirements

Where applicable, data protection obligations may be further governed by written agreements, including Data Processing Addenda.

Ethical Conduct and Business Integrity

XONIK expects all individuals acting on its behalf to conduct themselves with integrity and professionalism.

Our standards promote:

• Prohibition of bribery, corruption, and improper influence
• Honest and fair business dealings
• Responsible management of conflicts of interest
• Respectful treatment of individuals and organizations

Ethical conduct is a shared responsibility and a condition of engagement with XONIK.

Third-Party Relationships

XONIK engages third parties, including suppliers, contractors, and partners, as part of its global operations.

While XONIK does not own, operate, or control third-party operations or labor practices, we:

• Set ethical and compliance expectations through contractual and commercial arrangements where appropriate
• Apply proportionate due diligence based on the nature of the relationship and risk profile
• Reserve the right to engage, review, or disengage where material compliance concerns are identified

Third parties remain responsible for their own compliance with applicable laws and regulations.

Reporting Concerns and Whistleblowing

XONIK encourages the reporting of concerns relating to:

• Legal or regulatory non-compliance
• Ethical misconduct or integrity issues
• Data protection or information security incidents
• Human rights or labor-related concerns

Concerns may be reported confidentially to:

Legal & Compliance
Email: legal@xonik.com

Reports are reviewed and addressed in accordance with applicable laws and internal procedures. Retaliation against individuals who raise concerns in good faith is not tolerated.

Training and Awareness

XONIK promotes compliance awareness through:

• Internal guidance and communications
• Role-appropriate training, where relevant
• Ongoing assessment of compliance risks and obligations

Training and awareness initiatives are tailored to business context and risk exposure.

Continuous Improvement

XONIK recognizes that legal, regulatory, and ethical expectations evolve.

We are committed to:

• Monitoring relevant legal and regulatory developments
• Periodically reviewing and refining compliance practices
• Enhancing controls and processes as business activities and risk profiles change

Compliance is treated as an ongoing process of improvement, not a static obligation.

Limitations and No Guarantees

While XONIK takes compliance seriously and applies reasonable efforts to meet applicable obligations, no system or process can guarantee absolute compliance in all circumstances.

Compliance activities are subject to applicable laws, contractual terms, operational realities, and the inherent limitations of complex global operations.

Relationship to Other Policies and Agreements

This Compliance & Ethics page should be read together with XONIK’s:

• Privacy Policy
• Terms of Service
• Cookie Notice
• Accessibility Statement
• Anti-Slavery and Human Trafficking Statement

Where applicable, written agreements and contractual documents govern specific obligations and prevail in the event of any inconsistency.

Updates to This Page

XONIK may update this Compliance & Ethics page periodically to reflect changes in law, regulation, or business operations.

Updates will be posted with a revised effective date.

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