Code of Conduct

Last updated: May 31, 2026

1. Introduction

NextGen Conversations Corp (the "Company"), operating commercially under the WeSpeak brand, is committed to conducting its business with the highest standards of ethics, integrity, and legal compliance. This Code of Conduct and Anti-Corruption Policy (the "Code") applies to all directors, officers, employees, contractors, agents, representatives, and business partners of the Company ("Covered Personnel") in every country in which the Company operates.

2. Prohibition of Bribery and Corruption

The Company strictly prohibits any form of bribery or corruption, whether public or private, direct or indirect. Covered Personnel shall NOT, under any circumstances:

  • Offer, promise, authorize, give, or receive any payment, gift, commission, advantage, or anything of value for the purpose of improperly influencing a business, governmental, or regulatory decision.
  • Make "facilitation payments" to expedite administrative procedures, even in jurisdictions where they are not expressly prohibited by local law.
  • Use third parties (agents, intermediaries, consultants, partners, or distributors) to make payments or engage in conduct that the Company would be prohibited from carrying out directly.

The Company complies with applicable anti-corruption laws, including but not limited to the United States Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any anti-corruption regulations of the jurisdictions in which it operates.

3. Gifts, Invitations, and Hospitality

Gifts and business courtesies are acceptable only when:

  • They are of symbolic and reasonable value according to standard industry practice.
  • They are not in cash or cash equivalents (gift cards, cryptocurrency, transfers, etc.).
  • They are not offered or received with the expectation of preferential treatment.
  • They are transparent and can be openly disclosed without embarrassment to the Company.
  • They comply with applicable local law.

Any gift, invitation, or courtesy exceeding the Company's internal thresholds must be approved in writing by management. Offering or receiving any gift, hospitality, or courtesy to or from public officials is strictly prohibited without prior written authorization from management.

4. Interactions with Public Officials

Covered Personnel must exercise particular diligence in their interactions with public officials, including employees of state-owned or government-controlled entities. Any payment, gift, or offer to a public official requires prior written approval from Company management.

5. Political Contributions and Donations

The Company does not make political contributions on behalf of the organization. Any charitable donation or sponsorship must be approved by management, properly documented, and may not be used as a mechanism to obtain undue business advantage.

6. Conflicts of Interest

Covered Personnel must avoid situations where their personal, financial, or family interests may conflict with the interests of the Company. Any actual or potential conflict must be promptly disclosed in writing to management.

7. Accounting Records and Internal Controls

The Company maintains books, records, and accounts that accurately, completely, and reasonably reflect all transactions carried out. It is prohibited to:

  • Create false, incomplete, or misleading records.
  • Maintain unrecorded funds or accounts.
  • Make undocumented or unauthorized payments.

8. Relationships with Business Partners

The Company expects its partners, suppliers, distributors, and other business associates to operate under ethical standards equivalent to those described in this Code. The Company reserves the right to terminate any business relationship with third parties who breach these principles.

9. Data Protection and Confidentiality

Covered Personnel must protect the confidential information of the Company, its clients, and business partners, and comply with applicable data protection regulations.

10. Reporting Channel and Non-Retaliation

Any person who suspects or becomes aware of a possible violation of this Code may report it confidentially to: finanzas@wespeak.pro. The Company strictly prohibits any retaliation against individuals who, in good faith, report a possible violation or cooperate in an investigation. All reports will be handled seriously, confidentially, and diligently.

11. Consequences of Non-Compliance

Failure to comply with this Code may result in disciplinary action, including termination of employment or contractual relationship, as well as any legal action that may apply under applicable law.

12. Effective Date and Updates

This Code is effective as of its publication date and shall be periodically reviewed by Company management. Updated versions will be available on this website.

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