Nixxy, Inc.

Evaluation of Disclosure Controls and Procedures

Our principal executive officer and principal financial officer, with the assistance of management, evaluated the effectiveness of the Company’s disclosure controls and procedures as of June 30, 2025. Based on this evaluation, they concluded that disclosure controls and procedures were not fully effective due to previously identified material weaknesses in internal control over financial reporting.

However, during the second quarter of 2025, the Company initiated and implemented key remediation measures designed to strengthen internal controls, improve oversight, and enhance financial reporting processes. Management believes these actions represent substantial progress toward remediation and is actively monitoring the effectiveness of the updated controls.

Management is responsible for establishing and maintaining effective internal control over financial reporting. These controls are designed to provide reasonable assurance regarding the reliability of financial reporting and compliance with GAAP.

As of June 30, 2025, management assessed the Company’s internal control over financial reporting under the COSO 2013 framework. Based on this assessment, the Company concluded that internal control over financial reporting was not fully effective due to the material weaknesses identified in prior periods, including:

Remediation Actions Taken:

While these actions have materially enhanced the Company’s internal controls, management will continue to monitor their consistent application. As such, the material weaknesses are considered ongoing as of this reporting date but are expected to be fully remediated in the near term.

Changes in Internal Control over Financial Reporting

We have worked to establish all the checks and balances needed for all financial areas of our business. We hired a consultant in mid-2020 to establish best practices and help us document and implement these. This consultant is a CPA and has a significant background in running the accounting and budgeting process for public companies. We began adopting these best practices during the fourth quarter of 2020. We retained an outsourced firm with a panel of CPA consultants in 2021 to assist in building internal controls and preparing financial reports.