ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

XO Henning

Effective Date: June 2026

1. Purpose

XO Henning is committed to conducting business ethically, honestly, and in compliance with all applicable anti-bribery and anti-corruption laws.

This policy outlines our commitment to preventing bribery and corruption in all business activities.

2. Scope

This policy applies to all business activities carried out by XO Henning, including the sale of artworks to private collectors, businesses, galleries, and institutions.

3. Prohibition of Bribery

XO Henning prohibits any form of bribery or corrupt conduct.

No employee, representative, contractor, or person acting on behalf of XO Henning may:

- offer, promise, give, request, or accept bribes;

- provide improper payments or benefits to influence business decisions;

- make facilitation payments to government officials or private individuals.

4. Gifts and Hospitality

Reasonable gifts and hospitality that are lawful, modest in value, and customary in the ordinary course of business may be accepted or provided.

Any gift or benefit intended to improperly influence a decision is strictly prohibited.

5. Business Relationships

XO Henning seeks to conduct business only with reputable customers, suppliers, galleries, and service providers.

Transactions that appear suspicious or inconsistent with legitimate business practices may be declined.

6. Financial Controls

XO Henning maintains accurate records of business transactions, including invoices and payment documentation.

Payments are accepted only through recognized financial institutions and payment providers.

Cash payments are not accepted for online transactions.

7. Reporting Concerns

Any concerns regarding suspected bribery or unethical conduct will be investigated promptly and appropriately.

8. Compliance

Failure to comply with this policy may result in the termination of business relationships where appropriate.

XO Henning reviews this policy periodically to ensure continued compliance with applicable laws and best practices.

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Signed,

Henning Schulze

Founder, XO Henning

Germany

Date: 11.6.2026