Governance

Anti-Bribery and Corruption Statement

Capital57's approach to bribery and corruption risk across our operations, supply chain, and portfolio.

Effective date: 12 July 2026Last updated: 12 July 2026

Our commitment

Capital57 Ventures Pty Ltd ("Capital57") is committed to conducting its business honestly and with the highest standards of integrity. We adopt a zero-tolerance approach to bribery and corruption in all its forms.

1.

Scope

This statement applies to Capital57, its directors, officers, employees, contractors, advisers, and any third party acting on our behalf, including affiliated platform partners.

2.

Applicable law

We conduct our business in compliance with the anti-bribery and corruption laws that apply to our operations, including Division 70 of the Australian Criminal Code (foreign bribery), the UK Bribery Act 2010, and the US Foreign Corrupt Practices Act where applicable to our activities.

3.

Prohibited conduct

We do not offer, give, request, or accept, directly or through any intermediary, any financial or other advantage that is intended to induce the improper performance of a function or activity, or as a reward for such performance.

4.

Facilitation payments

We do not make facilitation payments of any kind, in any jurisdiction, regardless of local custom.

5.

Gifts and hospitality

Reasonable, proportionate, and openly offered business gifts and hospitality are permitted where they are consistent with local law, are of modest value, and could not reasonably be perceived as intended to influence any business decision. Anything beyond that threshold requires prior written approval from Capital57's Managing Director.

6.

Third parties

We conduct proportionate due diligence on the third parties with whom we do business, including portfolio companies, service providers, and introducers. We reserve the right to terminate any relationship in which we have reasonable grounds to suspect bribery or corruption.

7.

Portfolio companies

We expect the founders and management teams of our portfolio companies to adopt anti-bribery and corruption practices consistent with this statement, and we support them in doing so.

8.

Reporting concerns

Any individual with a concern about actual or suspected bribery or corruption involving Capital57 or its associated persons may report it in confidence to the address below. Reports are treated confidentially and the reporter is protected from retaliation. Where legal obligations require, matters will be escalated to the relevant regulator or law enforcement authority.

Capital57 Ventures Pty Ltd
[to be inserted at publication]
9.

Governance

This statement is reviewed annually by the Managing Director and, in due course, by the Board of Capital57 Ventures Pty Ltd. Material updates are published on the Site.