Anti-Bribery and Anti-Money Laundering Policy Statement

The Company operates a zero-tolerance policy to bribery and money laundering. It expects all our employees and supply chain to maintain the highest standards of ethical conduct and integrity and to comply with the UK Bribery Act 2010, Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and all applicable UK and international laws in relation to Bribery and Money Laundering, herein called the “Applicable Laws”.

This policy covers all Company business activities and applies to its directors, officers, employees (staff, contract and temporary) and any other person who performs services for or on behalf of the Company, herein addressed as “Associated Person’s”. It applies to bribery of any person regardless of their capacity or status including public/government officials and of private citizens and corporate bodies.

The Directors strongly require ethical business practices and compliance with all Applicable Laws. We are commitment to educating and training all persons working for the company regarding the Applicable Laws and the responsibility of every person comply with the law. Strict compliance with the requirements of this policy is mandatory.

Any Associated Person of the Company who knowingly fosters illegal conduct, ignores suspicious circumstances or fails to comply with the Applicable Laws or the Company’s Anti-Bribery and Anti-Money Laundering Policy and related procedures will, in the case of officers or employees of the Company, be subject to discipline, including possible termination of employment and, in the case of third parties performing services for or on behalf of the Company, be subject to contractual penalties including possible termination of their engagement.

This policy will be issued to all staff who will be trained and required to sign a certificate of compliance yearly. The policy will be available on our website for suppliers and third parties.

This Policy must be applied to all dealings between the Company, its subsidiaries and affiliates or any of them and with joint venture partners, agents, contractors, suppliers of goods and services and any other third party with whom the Company or any of its subsidiaries or affiliates enters into contractual relations of any kind.