Anti-Bribery Policy

Ultimate Cell UK Ltd – Anti-Bribery and Corruption Policy

Purpose

Ultimate Cell UK Ltd is fully committed to complying with the UK Bribery Act 2010 and maintaining the highest
ethical standards in all business operations. This policy establishes our zero-tolerance approach to bribery
and corruption.

Scope

This policy applies to all employees, officers, directors, contractors, consultants, subsidiaries, and any third
parties representing or acting on behalf of the Company.

Policy Statement

Ultimate Cell UK Ltd prohibits the offering, giving, soliciting, or receiving of any bribe, facilitation payment, or
other improper advantage. No employee or associated person shall engage in or condone any form of bribery
to secure a commercial, contractual, regulatory, or personal benefit.

Prohibited Conduct

• Offering, giving, requesting, or accepting any bribe or inducement, whether in cash or in kind.
• Making or authorising facilitation payments or kickbacks.
• Concealing or misrepresenting the nature of a transaction.
• Failing to report suspected bribery or corruption.

Gifts, Hospitality and Donations

Hospitality and promotional expenditure must be transparent, proportionate, and not intended to influence
decision-making. Any gift or hospitality above £50 must be declared to the Compliance Officer. Charitable
donations must not be used as a means of obtaining advantage.

Due Diligence

All third-party intermediaries, suppliers, and representatives must undergo due diligence before engagement
to ensure integrity and compliance.

Reporting and Whistleblowing

Employees and associated persons are required to report any suspicion or knowledge of bribery or corruption
immediately to the Compliance Officer or via the confidential reporting system. Reports made in good faith will
be treated confidentially, and individuals will be protected from retaliation.

Training and Communication

All employees will receive training on this policy at induction and refresher sessions at least every two years.
Managers are responsible for promoting compliance throughout their teams.

Record-Keeping

Accurate records of financial transactions, gifts, hospitality, and expenses must be maintained to ensure
transparency and auditability.

Disciplinary Action

Violations of this policy will result in disciplinary measures, including termination of employment or contract
and potential legal proceedings.

Review

This policy will be reviewed annually or sooner if significant changes occur in law or company operations.