Effective Date: January 13, 2025

byTokn International Corp (“byTokn,” “we,” “us,” or “our”) is committed to conducting business in accordance with all applicable laws, regulations, and ethical standards in every market where we operate. This Compliance Policy outlines the principles and expectations for both our internal practices and our relationships with customers, referral partners, and third parties. Adherence to this policy is fundamental to how we conduct business and manage our professional obligations.

Scope

This Compliance Policy applies to all employees, officers, and directors of byTokn, as well as to vendors, contractors, consultants, agents, and any other third-party representatives who are engaged in business with or on behalf of byTokn.

Compliance Objectives

Our compliance objectives are designed to ensure that all business dealings are conducted legally and ethically:

1. Legal Compliance: Comply with all laws, rules, and regulations that govern our operations in every jurisdiction where we operate.
2. Ethical Conduct: Maintain the highest standards of integrity and conduct to ensure that our business practices are fair and transparent.
3. Conflict of Interest: Identify and manage conflicts of interest, both actual and perceived, among our employees and in our business relationships.
4. Data Protection and Privacy: Ensure the integrity and confidentiality of personal and sensitive information of our customers, partners, and employees.
5. Anti-Bribery and Corruption: Prevent, detect, and respond to any instances of corruption and bribery, ensuring that all business is conducted in a fair and competitive manner.

Compliance Practices

1. Compliance Training and Awareness
   • Mandatory compliance training for all new employees and annual training for all employees to reinforce our standards and procedures.
   • Specific training modules based on roles and responsibilities, particularly for employees in sensitive positions.
2. Monitoring and Auditing
   • Regular audits and reviews to assess compliance with this policy, as well as with legal and regulatory requirements.
   • Systems and controls to monitor transactions and flag potential compliance issues.
3. Reporting and Whistleblowing
   • A clear process for reporting violations of laws, regulations, or this policy, without fear of retaliation.
   • Protection for whistleblowers to ensure that any report of non-compliance is dealt with confidentially and professionally.
4. Risk Management
   • Assessment of compliance risks as part of our strategic planning and decision-making processes.
   • Implementation of risk mitigation strategies tailored to specific areas of our operations.
5. Third-Party and Partner Compliance
   • Due diligence procedures for all new partners, suppliers, and third-party agents to ensure compatibility with byTokn’s compliance standards.
   • Requirements for contractual partners to adhere to comparable compliance standards and practices.
6. Enforcement and Remediation
   • Appropriate disciplinary actions for violations of this policy.
   • Remediation of any issues identified as a result of compliance failures or breaches.

Compliance Governance

The governance structure of our compliance program is designed to provide oversight and accountability:

• Compliance Officer: Appointed to oversee the development, implementation, and adherence to our compliance policy and related procedures.
• Compliance Committee: Comprising senior leadership, responsible for setting strategic compliance goals and ensuring integration of compliance into overall business operations.
• Board of Directors: Provides oversight and ensures that sufficient resources are allocated to maintain an effective compliance program.

Changes to the Compliance Policy

byTokn reserves the right to amend this policy at any time to reflect changes in law, regulatory requirements, or our business operations. We will communicate any changes to this policy to all affected parties.

Contact Information

For questions or concerns about compliance or this policy, please contact:

Camilo Lozada

clozada@bytokn.com

info@bytokn.com

Conclusion

byTokn is committed to upholding the highest standards of legal and ethical conduct. This Compliance Policy is central to our business practices and our corporate reputation. We expect every byTokn employee and our business partners to embrace the principles of this policy as a fundamental part of their relationship with our company. Compliance is everyone’s responsibility, and we rely on each individual to uphold these standards and to act proactively to ensure that byTokn maintains its commitment to lawful and ethical conduct.