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Governance

Code of Ethics & Business Conduct

Effective 7 June 2026

Trust is the foundation of everything Nexma builds. This Code states the standards of honesty, integrity, and responsibility we hold ourselves to — and how to raise a concern when something falls short.

1. Purpose and Who This Covers

This Code of Ethics and Business Conduct (the "Code") sets the standards of integrity expected of everyone who acts for Nexma — its directors, officers, employees, contractors, and agents. It does not address every situation but states the principles that guide how we work, build, and make decisions. Where a law or a specific Nexma policy is more demanding than the Code, the more demanding standard applies.

2. Integrity and Legal Compliance

We comply with the laws and regulations of the jurisdictions in which we operate, and we act honestly and in good faith in all dealings. No business goal justifies a violation of the law or of this Code. If a law conflicts with the Code, we follow the law; if the Code sets a higher standard than local custom, we follow the Code.

3. Conflicts of Interest

We make decisions in Nexma's interest, not for personal gain. A conflict of interest arises when a personal, financial, or outside relationship could improperly influence — or appear to influence — our judgment. Actual and potential conflicts must be disclosed promptly so they can be reviewed and managed.

4. Confidentiality and Data Protection

We protect confidential information entrusted to us by Nexma, our customers, and our partners, and we use it only for authorized purposes. We handle personal data in accordance with applicable data-protection laws and Nexma's privacy commitments, and we respect the intellectual property of others.

5. Responsible Use of AI and Spatial Intelligence

Nexma builds spatial intelligence that informs real-world decisions. We develop and deploy it responsibly: keeping humans accountable for consequential decisions, being transparent about capabilities and limitations, and declining uses that are unlawful or that contravene Nexma's safety and human-rights commitments. Our approach is described further in our Responsible AI policy and our Safety overview.

6. Fair Dealing and Competition

We compete vigorously but fairly. We do not engage in anti-competitive agreements, abuse of market position, or deceptive practices, and we comply with applicable competition and antitrust laws. We deal honestly with customers, suppliers, competitors, and colleagues.

7. Gifts, Entertainment, and Anti-Corruption

We do not offer or accept anything intended to improperly influence a business decision. Gifts and hospitality must be modest, lawful, and transparent. Bribery and corruption are prohibited in every form, as set out in our Anti-Bribery & Anti-Corruption Policy.

8. Protecting Company Assets and Accurate Records

We safeguard Nexma's physical, financial, and information assets against loss, theft, and misuse. We keep accurate and complete books and records, and we never falsify documents or misrepresent facts in Nexma's records, reports, or communications.

9. Respect for People

We treat one another and everyone we work with fairly and with respect. We are committed to a workplace free of discrimination, harassment, and retaliation, and to the health and safety of our people, as further described in our Nondiscrimination & Anti-Harassment Policy and our Human Rights Statement.

10. Raising Concerns and Non-Retaliation

If you believe the Code, the law, or a Nexma policy has been or may be violated, speak up. Concerns may be raised with leadership or through Nexma's reporting channels and may be reported to the contact below. Nexma investigates concerns raised in good faith and prohibits retaliation against anyone who reports honestly.

11. Enforcement

Adherence to the Code is a condition of working with and for Nexma. Violations may result in disciplinary action up to and including termination, and may carry legal consequences. The Code is reviewed periodically and updated as our business and obligations evolve.

Questions about this policy? Contact legal@nexma.ai.