Serendib Capital UK (the “Company”) is committed to conducting its business activities with integrity, transparency, and in full compliance with all applicable laws and regulations. This Anti-Corruption and Bribery Policy outlines the principles and standards that all employees, officers, directors, and agents of the Company (collectively referred to as “Team Members”) must adhere to in order to prevent corruption, bribery, and unethical conduct in all aspects of our business.

2. Anti-Corruption Commitment

The Company strictly prohibits any form of corruption, bribery, or unethical behavior, whether direct or indirect, and regardless of the individuals or entities involved. This policy applies to all Team Members and extends to interactions with clients, business partners, government officials, and other third parties.

3. Definitions

• Corruption: Any act or attempt to influence or manipulate a person’s actions or decisions, including government officials, through unethical, illegal, or improper means.
• Bribery: The offering, giving, receiving, or soliciting of anything of value to influence a decision or action, either directly or indirectly.

4. Compliance with Applicable Laws

Team Members must comply with all UK laws and regulations related to anti-corruption, bribery, and ethical conduct, including but not limited to the UK Bribery Act 2010.

5. Prohibited Activities

Team Members are strictly prohibited from engaging in the following activities:

• Offering, giving, promising, or receiving bribes, kickbacks, or any form of improper inducements.
• Using Company funds or assets for any illegal or unethical purposes.
• Engaging in facilitation payments to expedite routine government actions.
• Participating in money laundering, embezzlement, or any financial irregularities.
• Providing preferential treatment or benefits to government officials or business partners to gain an unfair advantage.

6. Due Diligence and Third-Party Vetting

The Company will conduct thorough due diligence on third parties, including suppliers, contractors, agents, and business partners, to ensure they adhere to ethical and legal standards. Team Members must report any concerns regarding the ethical conduct of third parties to the Compliance Officer.

7. Reporting Violations

Team Members who suspect or witness any violation of this policy must promptly report their concerns to the Company’s Compliance Officer or any other designated authority. The Company is committed to protecting whistleblowers and will not tolerate any retaliation against those who report in good faith.

8. Consequences of Violations

Violations of this Anti-Corruption and Bribery Policy may result in disciplinary action, up to and including termination of employment or contractual relationship. The Company may also pursue legal action against those involved in corrupt or unethical conduct.

9. Training and Awareness

The Company will provide anti-corruption and bribery training to Team Members to ensure their understanding of this policy and relevant legal requirements.

10. Regular Review and Updates

This Anti-Corruption and Bribery Policy will be reviewed periodically to ensure its effectiveness and relevance. Updates will be made as necessary to align with changing legal standards and business needs.