1. PURPOSE AND REGULATORY CONTEXT

This Policy is adopted in accordance with:

• applicable UAE Federal laws on bribery and corruption;
• relevant international anti-corruption standards.

2. SCOPE AND APPLICABILITY

This Policy applies to:

• all employees of Cregis;
• members of the Board of Directors;
• Senior Management;
• contractors, consultants, secondees, and temporary staff; and
• third parties acting for or on behalf of Cregis, including agents, introducers, and service providers.

Compliance with this Policy is mandatory and forms part of the Company's internal control framework.

3. DEFINITIONS

For the purposes of this Policy:

• Bribery - The offering, promising, giving, receiving, or soliciting of any financial or other advantage, directly or indirectly, to influence the actions, decisions, or conduct of an individual in order to obtain or retain business or secure an improper advantage.
• Corruption - The abuse of entrusted power, position, or authority for private gain, including but not limited to bribery, fraud, embezzlement, facilitation payments, and other unethical or unlawful conduct.
• Public Official - Any person holding a legislative, administrative, or judicial office, whether appointed or elected, at any level of government (local, national, or international), including employees of state-owned or state-controlled entities, public agencies, international organizations, political parties, or candidates for public office.

4. ZERO-TOLERANCE STATEMENT

• Cregis Custody FZE strictly prohibits all forms of bribery or corruption, whether direct or indirect, including offering, giving, soliciting, or accepting any improper advantage.
• No employee or associated person is permitted to offer, give, solicit, or accept a bribe, facilitation payment, or improper advantage in connection with Cregis's business.

5. GIFTS, HOSPITALITY, AND BENEFITS

Gifts, hospitality, or entertainment may be offered or accepted only where all of the following conditions are met:

• the item is reasonable, proportionate, and infrequent;
• it is not intended to influence, or perceived as influencing, a business decision;
• it is lawful and culturally appropriate; and
• it is properly declared and recorded.

The following are prohibited at all times:

• cash or cash equivalents;
• gifts or hospitality offered during sensitive decision making periods;
• gifts or benefits involving Public Officials without prior Compliance approval.

Cregis maintains a record of all declared items given or received, together with the relevant and required approvals.

6. FACILITATION PAYMENTS

Facilitation payments (i.e. payments made to secure routine governmental actions) are strictly prohibited.

7. THIRD-PARTY AND PARTNER RISK

Cregis shall conduct appropriate due diligence on third parties prior to engagement and on an ongoing basis. Contracts with third parties must include anti-bribery and corruption clauses where applicable.

Cregis will not engage with any third party where there is a reasonable belief that bribery or corruption risks cannot be adequately mitigated.

8. RESPONSIBILITIES AND GOVERNANCE

• Board of Directors:
• Senior Management:
• Compliance Officer:
• Employees and Associated Persons:

9. REPORTING AND WHISTLEBLOWING

Any suspected bribery or corruption must be reported immediately through the Company's whistleblowing channels. Reports may be made confidentially and, where legally permissible, anonymously. Retaliation against individuals who report concerns in good faith is strictly prohibited.

10. INVESTIGATION AND ESCALATION

All reports will be assessed and investigated by the Compliance Officer in fair and independent manner. Material incidents shall be escalated to Senior Management and the Board, and reported to VARA or other competent authorities where required by law or regulation.

11. RECORD KEEPING

Cregis shall maintain accurate and complete records relating to:

• gifts and hospitality;
• third party due diligence;
• investigations and outcomes.

All records shall be retained for a minimum of 8 years as per regulatory requirements.

12. TRAINING AND AWARENESS

Cregis shall provide regular training to employees and relevant third parties on anti-bribery and corruption risks, obligations, and reporting mechanisms.

13. BREACHES AND DISCIPLINARY ACTION

Breaches of this Policy may result in disciplinary action, including termination of employment or engagement. Serious breaches may also give rise to civil or criminal liability under UAE law.

14. REVIEW AND GOVERNING LAW

This Policy shall be reviewed at least annually and updated to reflect regulatory or business changes.

This Policy is governed by the laws of the Emirate of Dubai and applicable federal laws of the UAE.