Serendib Capital Limited is committed to maintaining the highest standards of ethical and legal conduct in all of its operations. This Anti-Money Laundering (AML) Policy is designed to prevent the use of our services for any illegal activities, including money laundering and terrorist financing. This policy applies to all employees, agents, and partners of Serendib Capital Limited.

2. Compliance with AML Laws

Serendib Capital Limited is fully committed to complying with all applicable AML laws and regulations in the jurisdictions where we operate. We will conduct ongoing due diligence on our customers and transactions to detect and report any suspicious activities.

3. Customer Due Diligence (CDD)

• We will perform customer due diligence to verify the identity of our customers.
• We will assess the risk associated with each customer based on their business activities, geographic location, and other relevant factors.
• Enhanced due diligence will be conducted for high-risk customers.

4. Reporting and Record Keeping

• Serendib Capital Limited will maintain records of customer identification, transactions, and all AML-related documentation.
• We will promptly report any suspicious transactions to the relevant authorities in accordance with applicable laws.

5. Employee Training

• All employees will receive training on AML policies and procedures.
• We will provide ongoing training to keep employees informed of changes in AML laws and regulations.

6. Reporting Violations

• Any employee who suspects a violation of this policy is obligated to report it to the designated AML compliance officer.
• Employees reporting violations in good faith will be protected from retaliation.

7. Penalties

• Violation of this AML policy may result in disciplinary action, including termination of employment.
• Serendib Capital Limited may also report violations to law enforcement authorities as required.

Anti-Bribery and Corruption Policy

1. Introduction

Serendib Capital Limited is dedicated to conducting its business with the utmost integrity and in full compliance with all anti-bribery and anti-corruption laws. This Anti-Bribery and Corruption Policy outlines our commitment to preventing bribery and corruption in all our operations.

2. Compliance with Anti-Bribery Laws

• Serendib Capital Limited is fully committed to adhering to all applicable anti-bribery laws and regulations in the jurisdictions where we operate.
• We will not engage in any form of bribery, whether involving public officials, private individuals, or entities.

3. Prohibited Activities

• It is strictly prohibited to offer, promise, give, request, or accept bribes or kickbacks in any form.
• Facilitation payments are also prohibited, except where explicitly permitted by local laws.

4. Gifts, Hospitality, and Expenses

• Gifts and hospitality must be reasonable, transparent, and consistent with local customs and laws.
• Approval processes for gifts and expenses must be followed.

5. Reporting and Whistleblowing

• Employees are encouraged to report any suspected acts of bribery or corruption to the designated compliance officer or through our confidential whistleblower reporting channels.
• Serendib Capital Limited will protect whistleblowers from retaliation and maintain their anonymity to the extent permitted by law.

6. Training and Education

• All employees will receive training on anti-bribery and anti-corruption policies and procedures.
• Training will be ongoing to ensure awareness and compliance.

7. Penalties

• Violation of this Anti-Bribery and Corruption Policy may result in disciplinary action, including termination of employment.
• Serendib Capital Limited may also report violations to law enforcement authorities as required.

These filled-in policies reflect Serendib Capital Limited’s commitment to ethical conduct and legal compliance. All employees and stakeholders are expected to adhere to these policies without exception.