Anti-Bribery and Corruption Policy

This policy communicates to all external parties PunkFox’s position on bribery and corruption and applies to all business dealings in Australia and globally.

1. Our Commitment: Zero Tolerance

PunkFox (trading as Visibull Limited) conducts all business in an honest and ethical manner, maintaining a zero-tolerance approach to bribery and corruption.

• We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.
• We uphold all relevant laws in Australia and the jurisdictions in which we operate. As a business with global influence, we also maintain standards consistent with the UK Bribery Act 2010.
• We take our legal responsibilities seriously, recognising that breaches can result in severe penalties, including substantial fines and reputational damage.

2. Policy Scope and Application

This policy applies to:

(a) All Associated Individuals: All individuals working for or on behalf of PunkFox, including managers, directors, employees, consultants, and contractors.

(b) Third Parties: Any individual or organisation we interact with, including clients, customers, suppliers, distributors, business contacts, agents, advisors, and government officials.

When we engage with third parties, we conduct appropriate due diligence to ensure they comply with the principles outlined in this policy.

3. What is Not Acceptable?

A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage. Corruption is the misuse of office or power for private gain.

PunkFox does not (and does not procure someone to):

• Offer, promise, or give any payment, gift, or hospitality with the expectation that a business advantage will be received in return.
• Offer or accept a gift, hospitality, or payment if we know or suspect it is intended to secure an improper business advantage for us or a third party.
• Make or accept “facilitation payments” (small, unofficial payments to secure or expedite routine government action) or “kickbacks” (payments made in return for a business favour or advantage).
• Threaten or retaliate against anyone who refuses to commit a bribery offence or raises concerns under this policy.

4. Donations and Political Contributions

• We do not make contributions to political parties.
• We only make charitable donations that are legal, ethical, and fully transparent under local laws and practices.

5. Raising a Concern (Reporting Malpractice)

We encourage all third parties to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.

Any concerns or issues should be referred to our dedicated internal channel:

• Contact: The Compliance Officer
• Email: ben@punkfox.com.au (Please use this email for all legal and ethical enquiries)
• Phone: +61 08 65581890

6. Monitoring and Review

We are committed to continuously monitoring the effectiveness and reviewing the implementation of this policy, ensuring its suitability and adequacy in countering bribery and corruption risk across our operations.