Earnpark Limited, a company incorporated under the Business Company Act of the British Virgin Islands under BVI registration number 2149760 on the 28th day of May, 2024, registered address: Intershore Chambers, Road Town, Tortola, British Virgin Islands (hereinafter referred to as the “Company”, “we”), is committed to conducting its Business with honesty and integrity and in compliance with the laws of all the countries in which the Company is active. This Policy has been developed in order to facilitate the observance of all relevant anti‐bribery and anti‐corruption laws and regulations, including, but not limited to, the Proceeds of Criminal Conduct Act 1997 and the Criminal Code 1997 of the Virgin Islands, as well as any other relevant legislation of the British Virgin Islands, and the United Nations Global Compact Business Principles and OECD recommendations regarding corruption.

It is the responsibility of everyone at the Company to prevent all forms of bribery, corruption and fraud, all breaches of sanctions laws, and to conduct the Company 's business in accordance with the highest standards of ethical behaviour at all times.

Eliminating bribery, corruption, and fraud benefits the communities in which we operate by promoting the rule of law, good governance, and fair, transparent, and ethical business.

This Policy sets out the Company's commitments to compliance with anti-bribery, corruption, fraud, and sanctions. It is also supported by standards and procedures setting out minimum requirements that apply to all persons and entities across the Company’s operations globally and to any person or entity who acts on the Company’s behalf.

The objective of this Policy is to:

The terms defined herein should be construed broadly to give effect to the letter and spirit of the law.

“Bribery” is the giving or receiving of money, a gift, a benefit, or any other advantage – financial or otherwise as an inducement to do something that is dishonest, illegal, a breach of trust in the course of doing business or to gain an unfair or improper advantage. Details hereto are provided below in article 5.2. of this Policy.

“Business” includes all normal business transactions of Earnpark Limited. “Covered Person(s)” shall mean all directors, employees, contractors on hire, and officers of the Company.

“Government or Public Officials” shall mean individuals who hold a legislative, administrative or judicial position of any kind, whether appointed or elected and/or exercises a public function for or on behalf of a country or territory.

“The Company” shall mean Earnpark Limited, a company incorporated under the Business Company Act of the British Virgin Islands under BVI registration number 2149760 on the 28th day of May, 2024, registered address: Intershore Chambers, Road Town, Tortola, British Virgin Islands.

“Officers of the Company” shall mean any director or company secretaries of the Company.

“Third Party/Parties” shall mean investors, users, service providers, and other business partners.

The Company takes a zero-tolerance approach to bribery and corruption and is committed to carrying out business fairly, honestly, openly, and without improper influence. The Company does not, either directly or indirectly, through intermediaries or other third parties, solicit, receive, offer, promise, or provide any financial or other advantage of material value or otherwise exercise improper influence in its dealings with other businesses or with the Government or Public Officials with the intention of obtaining any improper advantage in the conduct of its Business. All Covered Persons are required to comply with this Policy and are responsible for ensuring that the Company’s Business is undertaken with the utmost integrity with regard to the following matters:

5.1. Fraud and Extortion

Fraud and extortion are criminal offenses. The Company prohibits the direct or indirect demand for, or acceptance of, any advantage, through deception or otherwise, which is used for the Covered Person or The Company‘s benefit.

5.2. Bribery

The Company prohibits all forms of bribery whether or not the advantage, benefit, or improper performance may have been offered or received indirectly, for example, via a customer, investor, agent, intermediary, or supplier.

“Bribery” is the giving or receiving of money, a gift, a benefit, or any other advantage – financial or otherwise as an inducement to do something that is dishonest, illegal, a breach of trust in the course of doing business or to gain an unfair or improper advantage. Bribery occurs whether or not:

The Company strictly prohibits bribery and other related unlawful or improper payments or activities.

We will not bribe or attempt to improperly influence any person (including public officials) to act (or omit to act) in any way that differs from the proper performance of that person’s proper duties, obligations, role, or standards of conduct.

In particular, we will not:

Payments that would otherwise be prohibited under this Policy are permitted where there is an imminent explicit or implicit threat to personal safety.

5.3. Facilitation Payments

The Company prohibits facilitation payments. A facilitation payment is payment of a bribe to a government or other official to secure or expedite the performance of an action. In circumstances where the payment of a bribe or similar is demanded under duress, whether paid or not, this must immediately be reported to the Company’s Compliance Officer.

5.4. Sanctions

The Company is committed to ensuring full compliance with all financial, economic, and trade sanctions laws that apply to our global business. The Company requires strict compliance with sanctions. This means that we must always comply with our due diligence requirements and never engage in any transaction with a person or entity that is owned or controlled by or acting on behalf of persons or entities that are “designated” under Sanctions laws.

World-Check sanctions due diligence is conducted in relation to all vendors, and jurisdiction-specific information is sourced where available before onboarding vendors and is repeated annually.

The Company recognizes that fostering good relationships with business partners and customers is important to its continued success. The provision and receipt of modest gifts and entertainment and the incurring of modest expenses are acceptable in principle, provided that they are reasonable and made transparently.

However, the provision or receipt of any gift or entertainment, or the incurring of any expenses, is not permitted where it is offered or received in exchange for a business or other improper benefit, creates any sense of “obligation”, influences business judgment or creates a conflict between Covered Persons personal interests and those of the Company or is otherwise illegal. Any activity that could be perceived as having any of the above effects is also prohibited. The Company ‘s business decisions and those of third parties must be made objectively and without influence from gifts or favors.