Anti-Corruption and Bribery Policy

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Effective Date: 01 March 2024

Carbon1 Limited ("the Company") is committed to conducting business with integrity, transparency, and in compliance with all applicable laws and regulations. As part of this commitment, we have established this Anti-Corruption and Bribery Policy to outline our zero-tolerance approach to corruption and bribery in any form.

Compliance with Laws

The Company and all employees, contractors, and representatives acting on behalf of the Company must comply with all anti-corruption and bribery laws, regulations, and standards applicable in the jurisdictions where we operate. This includes, but is not limited to, the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any other relevant local laws.

Prohibited Conduct

The following conduct is strictly prohibited:

a. Offering, promising, giving, or receiving any bribe, kickback, or other improper payment or benefit to or from any person or entity, whether directly or indirectly, in order to obtain or retain business or gain any improper advantage.

b. Engaging in any form of corruption, including extortion, embezzlement, money laundering, or other illegal or unethical practices.

c. Providing gifts, entertainment, or hospitality that could be perceived as intended to improperly influence a business decision or gain an unfair advantage.

d. Engaging in any activity that may create a conflict of interest or compromise the Company's integrity or reputation.

Reporting Violations

Employees, contractors, and representatives are encouraged to report any suspected violations of this policy to their supervisor, Human Resources, or the Compliance Officer. Reports may be made anonymously, and no retaliation will be taken against individuals who report concerns in good faith.

Consequences of Violations

Violations of this policy will not be tolerated and may result in disciplinary action, up to and including termination of employment or contractual relationship. In addition, individuals found to have engaged in corrupt or fraudulent conduct may be subject to civil or criminal prosecution.

Due Diligence and Risk Assessment

The Company will conduct appropriate due diligence on all business partners, suppliers, and other third parties with whom we engage to assess their integrity and compliance with anti-corruption laws. We will also regularly assess and mitigate the risks of corruption and bribery in our business operations.

Training and Awareness

The Company will provide regular training and education to employees, contractors, and representatives on anti-corruption and bribery laws, policies, and procedures. This will help ensure that all individuals understand their obligations and responsibilities under this policy.

Review and Update

This policy will be reviewed periodically to ensure that it remains effective and up-to-date with changes in laws, regulations, and business practices. Any updates or revisions to the policy will be communicated to all relevant parties.