This policy aims to:

• Establish clear guidelines for preventing bribery and corruption.
• Foster a culture of ethical conduct and compliance.
• Protect the Company's reputation and assets.
• Ensure compliance with applicable laws and regulations.
• Provide a framework for reporting and investigating suspected bribery and corruption.

• Bribery: Offering, promising, giving, requesting, or accepting a financial or other advantage to induce or reward improper performance of a function or activity.
• Corruption: Abuse of entrusted power for private gain.
• Associated Person: Any employee, director, officer, contractor, agent, or other person or entity acting on behalf of the Company.
• Public Official: Any person holding a legislative, administrative, or judicial office of a country, territory, or local authority, or any person exercising a public function, including for a public agency or public enterprise.

The Company strictly prohibits:

• Offering, promising, or giving a bribe to any person, whether a Public Official or private individual.
• Requesting or accepting a bribe from any person.
• Facilitation payments (small payments made to secure or expedite routine government actions).
• Engaging in any form of corruption, including embezzlement, fraud, and money laundering.
• Failing to report suspected bribery or corruption.
• Retaliating against anyone who reports suspected bribery or corruption in good faith.

• Gifts and hospitality are permitted only if they are reasonable, proportionate, and made in good faith.
• Gifts and hospitality must never be offered or accepted with the intention of influencing a business decision.
• All gifts and hospitality exceeding a pre-defined value (to be specified in internal guidelines) must be recorded and approved.
• Cash gifts are strictly prohibited.
• Expenses must be accurately recorded and properly documented.

• The Company will conduct due diligence on all Associated Persons and business partners to assess the risk of bribery and corruption.
• Due diligence will be proportionate to the risk involved.
• Contracts with Associated Persons and business partners will include anti-bribery and anti-corruption clauses.

• All Associated Persons have a duty to report any suspected bribery or corruption.
• Reports can be made to Compliance Officer, Legal Department via Email to shyam@nartin.ae
• The Company will investigate all reports of suspected bribery or corruption promptly and thoroughly.
• The Company will maintain confidentiality to the maximum extent possible, consistent with applicable law, for those reporting suspicions.
• The Company has a Whistleblowing policy that protects those who report in good faith.

• The Company will provide regular training to all Associated Persons on this policy and related anti-bribery and anti-corruption laws.
• The Company will raise awareness of the risks of bribery and corruption through internal communications and other channels.

• The Company will regularly monitor its compliance with this policy.
• The Company will conduct periodic audits to assess the effectiveness of its anti-bribery and anti-corruption controls.
• Any breaches of this policy will be dealt with appropriately, which may include disciplinary action up to and including termination of employment or contract.

This policy and all matters arising from it shall be governed by and construed in accordance with the laws of the Dubai International Financial Centre (DIFC), Dubai, UAE. The Company submits to the exclusive jurisdiction of the Courts of the DIFC.

This policy will be reviewed and updated periodically to ensure its continued effectiveness and compliance with applicable laws and regulations.

This policy has been approved by the Senior Management of Nartin LLC FZC.

01-03-2025