Serendib Capital UK (the “Company”) is committed to maintaining the highest ethical and professional standards in all its business activities. This Code of Conduct Policy outlines the principles and standards of behavior expected from all employees, officers, directors, and agents of the Company (collectively referred to as “Team Members”). Adherence to these principles is essential to uphold the Company’s reputation and ensure its continued success.

1. Ethical Behavior:

• Team Members must act with honesty, integrity, and transparency in all business dealings.
• Avoid conflicts of interest and promptly disclose any potential conflicts to the appropriate authority within the Company.
• Do not engage in any form of bribery, corruption, or unethical practices.

2. Compliance with Laws and Regulations:

• Comply with all applicable UK laws, rules, and regulations.
• Seek guidance from the Compliance Officer when unsure about compliance with any law or regulation.

3. Confidentiality and Data Protection:

• Safeguard all confidential and proprietary information of the Company and its clients.
• Do not disclose or misuse confidential information, whether internal or external to the Company.
• Comply with data protection laws and policies when handling personal data.

4. Fair Competition:

• Compete fairly and honestly in the marketplace.
• Avoid practices that could harm competition or lead to anti-competitive behavior.

5. Conflict Resolution:

• Address conflicts and disputes with colleagues or business partners professionally and promptly.
• Report any unethical or illegal conduct to the appropriate authority within the Company.

6. Environmental Responsibility:

• Promote sustainability and environmentally responsible practices.
• Comply with all environmental laws and regulations relevant to the Company’s operations.

7. Health and Safety:

• Prioritize the health and safety of all Team Members and stakeholders.
• Comply with all health and safety regulations and take necessary precautions to prevent accidents and injuries.

8. Anti-Harassment and Non-Discrimination:

• Ensure a workplace free from discrimination, harassment, or retaliation based on race, gender, religion, age, disability, or any other protected status.
• Treat all colleagues and business partners with respect and dignity.

9. Reporting Violations:

• Team Members are encouraged to report any violations of this Code of Conduct to their supervisor or the Compliance Officer.
• The Company is committed to protecting whistleblowers from retaliation for reporting in good faith.

10. Consequences of Violations:

• Violations of this Code of Conduct may result in disciplinary action, up to and including termination of employment or contractual relationship.
• The Company may also pursue legal action in response to violations of law.

Conclusion: Every Team Member is responsible for upholding the principles and standards outlined in this Code of Conduct Policy. By adhering to these principles, we contribute to the continued success, integrity, and reputation of Serendib Capital UK.