Earnpark 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 UK Bribery Act 2010 and the United Nations Global Compact Business Principles and OECD recommendations regarding corruption.

It is the responsibility of everyone at Earnpark to prevent all forms of bribery, corruption and fraud, all breaches of sanctions laws, and to conductEarnpark'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 Earpark'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 Earnpark’s operations globally and to any person or entity who acts on Earnpark’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 Code.

“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 Platform LLP.

“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.

“Earnpark” or “the Company” shall EARNPARK PLATFORM LLP.

“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.

Earnpark takes a zero-tolerance approach to bribery and corruption and is committed to carrying out business fairly, honestly, openly, and without improper influence. Earnpark 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 Earnpark Business is undertaken with the utmost integrity with regard to the following matters:

5.1. Fraud and Extortion

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

5.2. Bribery

EarnPark 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:

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

Earnpark 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 theEarnpark Compliance Officer.

5.4. Sanctions

Earnpark is committed to ensuring full compliance with all financial, economic, and trade sanctions laws that apply to our global business. Earnpark 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.

Earnpark 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 Earnpark or is otherwise illegal. Any activity that could be perceived as having any of the above effects is also prohibited.Earnpark‘s business decisions and those of third parties must be made objectively and without influence from gifts or favors.