Anti-Bribery & Corruption Policy

Purpose and Commitment

Daro UK Ltd adopts a zero-tolerance approach to bribery and corruption and is committed to conducting all business activities professionally, fairly and with integrity, wherever it operates.

This Policy explains how Daro UK Ltd prevents, detects and responds to bribery, corruption and related economic crime. It reflects applicable legal and regulatory requirements as at 27 June 2025.

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Scope and Application

This Policy applies to all individuals working for or on behalf of Daro UK Ltd, at all levels and in all locations, including:

• Employees (permanent, fixed-term or temporary)

• Consultants, contractors and agency staff

• Seconded workers, volunteers and casual staff

• Agents, sponsors and representatives

• Any other person or entity performing services for or on behalf of Daro UK Ltd

All such individuals are referred to in this Policy as Workers.

Third Parties

A Third Party includes any individual or organisation that Workers may encounter during the course of business, including customers, suppliers, distributors, intermediaries, advisers, agents, government bodies, public officials, politicians and political parties.

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Legal and Regulatory Framework

Daro UK Ltd complies with all applicable anti-bribery and anti-corruption laws in the jurisdictions in which it operates, including but not limited to:

• The UK Bribery Act 2010

• Applicable local anti-corruption legislation

• Corporate criminal liability and “failure to prevent” offences under relevant economic crime legislation

Daro UK Ltd undertakes risk-based due diligence on suppliers, agents and business partners, including those operating in the USA, Germany, Denmark, Switzerland, Austria and other jurisdictions.

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What Is Bribery?

A bribe is any financial or other advantage offered, promised, given, requested or received in order to improperly influence a decision or to obtain an improper business or personal advantage.

Bribery offences include:

• Giving or offering a bribe

• Receiving or requesting a bribe

• Bribing a foreign public official

Daro UK Ltd may also be liable where it fails to prevent bribery by an associated person acting for its benefit.

Legitimate Official Payments

Official, lawful and receipted customs duties or import/export fees may be paid where required for legitimate business purposes. Such payments must be transparent, documented and accurately recorded in accordance with internal procedures.

Facilitation payments are strictly prohibited.

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Prohibited Conduct

Workers must never:

• Offer, promise or give any payment, gift or hospitality in expectation of an improper business advantage

• Request or accept any benefit intended to improperly influence a decision

• Provide anything of value to a government official to facilitate or expedite routine actions

• Accept benefits where improper intent is known or reasonably suspected

• Retaliate against anyone who refuses to engage in bribery or who raises concerns

• Engage in any activity that could reasonably result in a breach of this Policy

Facilitation Payments and Kickbacks

Daro UK Ltd does not make or accept facilitation payments, kickbacks or unofficial payments of any kind.

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Gifts and Hospitality

Reasonable and proportionate gifts and hospitality are permitted only where they comply with Daro UK Ltd’s internal procedures and the principles set out below.

All gifts and hospitality must:

• Not be intended to improperly influence any decision

• Comply with applicable local laws and regulations

• Be given in the name of Daro UK Ltd, not in an individual’s name

• Never include cash or cash equivalents

• Be appropriate, proportionate and reasonable in the circumstances

• Be given openly and transparently

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Regional and Cultural Considerations

Daro UK Ltd recognises that business practices may vary between countries and regions. However, the overriding test is whether the gift or hospitality is reasonable, justifiable and lawful both in the UK and in the relevant local jurisdiction.

Custom, tradition or local practice does not justify bribery.

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Charitable Donations and Sponsorship

Daro UK Ltd only makes charitable donations and sponsorships that are:

• Legal and ethical

• Consistent with local laws and practices

• Pre-approved by a Director

All charitable donations and sponsorships must be fully documented and accurately recorded.

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Record Keeping and Internal Controls

Daro UK Ltd maintains accurate and complete financial records and appropriate internal controls to demonstrate the legitimate business purpose of all payments, gifts and hospitality.

False, misleading or incomplete records are strictly prohibited.