Anti-Slavery and Human Trafficking Statement

1. Policy statement

   This anti-bribery policy (the “Policy”) sets out the responsibilities of 2Encapsulate Limited and it related entities (“2Encapsulate” or the “Company”) and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption. This Policy also acts as a source of information and guidance for those Third Parties (defined below) working with 2Encapsulate. It helps them recognize and deal with bribery and corruption issues, as well as understand their responsibilities. Specific red flags of bribery and corruption are described in the Annex to this Policy.

   2Encapsulate is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing effective systems that ensure bribery is prevented. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever we operate.

   2Encapsulate will uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, and of the U.S., including the Foreign Corrupt Practices Act, in regards to our conduct both at home and abroad.

   2Encapsulate recognizes that bribery and corruption undermine the rule of law and distort free and fair markets. Moreover, violations of anti-bribery laws may be punishable by civil and criminal penalties. If our company is found to have participated in corrupt activities or failed to prevent bribery undertaken on its behalf, we may face significant fines, disgorgement, costly supervision and review by an independent monitor, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with these consequences in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

   2. Definitions

   “Agent”: Any individual acting on the Company’s behalf in negotiating, transacting, or otherwise engaging with Third Parties.

   “Company”: 2Encapsulate, including all subsidiaries and affiliated companies.

   “Employee”: For the purposes of this Policy this includes all individuals working at all levels and grades, including directors, officers and other employees of the Company, including all permanent, fixed-term, and temporary employees, consultants, contractors, trainees, seconded staff, home-workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with the Company, wherever they are located.

   “Public Official”: Any individual holding a position in, or acting for, a government, political party, or public international organization. It does not matter if the individual is appointed or elected to their position, or a candidate for political office.

   “Third Part(y)(ies)”: Any individual or organization you or our Company come into contact with during the course of your work for us. This includes actual and potential customers, suppliers, business contacts, and intermediaries (such as Agents, distributors, consultants, sales representatives, implementation partners, sales partners), advisors, consultants, and government or public bodies, including their advisors, representatives and officials, politicians and political parties.

   3. Who is covered by this Policy?

   This Policy applies to all Employees. It also applies to Company officers, trustees, board, and/or committee members at any level.

   This Policy also acts as a source of information and guidance for those Third Parties working with 2Encapsulate. Any arrangements our Company makes with a Third Party must be subject to clear contractual terms, including specific provisions that require the Third Party to comply with standards and procedures relating to anti-bribery and corruption.

   4. Prohibition on Bribery

   Employees are prohibited from engaging in bribery of private commercial parties or Public Officials. Employees are also prohibited from receiving bribes.

   Bribery consists of offering, giving, paying, or promising or authorizing an offer, gift, or payment of anything of value to influence a private party of Public Official in their role, in order to obtain or retain business, or to improperly induce, influence, or reward a person for an improper action or decision relevant to that person’s role.

   Receiving a bribe consists of soliciting, agreeing to receive, or accepting a financial or other advantage in exchange for, or as a reward for, an improper action or decision relevant to an Employee’s role.

   A bribe can be any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

   Bribery is illegal. Employees must not engage in any form of bribery, whether directly or through a Third Party. They must not bribe a Public Official anywhere in the world. They must not accept bribes in any form, and if they are uncertain about whether something is a bribe or a permissible gift or act of hospitality, they should seek further advice from the Company’s General Counsel.

   It is strictly prohibited for Employees to (directly or through a Third Party):

   1. Give, promise to give, authorize, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

   2. Give, promise to give, authorize, or offer a payment, gift or hospitality to a Public Official or Third Party to facilitate or expedite a routine governmental action, even if one is legally entitled to that action without such payments;

   3. Accept a gift, payment, and/or hospitality from a Third Party that you know or suspect is offered with the expectation that you or 2Encapsulate will provide a business advantage to them in return;

   4. Threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this Policy; or

   5. Engage in any activity that might lead to an actual or apparent breach of this Policy or give the appearance of impropriety.

   5. What is and what is NOT acceptable

   This section of the Policy refers to 3 areas:

   • Gifts, invitations, and hospitality

   • Kickbacks

   • Political and charitable contributions

   Gifts, invitations, and hospitality

   In the course of its business, the Company and Employees may be offered gifts, invitations, or hospitality such as invitations to social functions, sporting events, meals, travel, and entertainment, or customary tokens of appreciations.

   In many circumstances, it is appropriate for the Company to provide or receive gifts, invitations, or other appropriate gestures of hospitality and goodwill. However, these must meet the following requirements:

   1. They are supported by an ethical, professional justification;

   2. They are not excessive in value, as pre-determined by the Company’s General Counsel (i.e. gifts in excess of £40 or $50);

   3. They are not provided to improperly induce or influence the recipient, to obtain or retain business or a business advantage, or as an explicit or implicit exchange for any favors or benefits;

   4. They are provided openly and transparently (in other words, not provided in a manner to hide it from the recipient’s superiors);

   5. They comply with the applicable law;

   6. They are not a gift of cash or a cash-equivalent, e.g. gift card, voucher, cryptocurrency, or securities;

   7. They are given in the name of the Company, not of an individual;

   8. They are of an appropriate type and value, and are given at an appropriate time under the circumstances (e.g. small gifts around a holiday or as a small thank you to a company for helping with a large project upon completion);

   9. They are not selectively given to a key, influential person with the intention of directly influencing them; and

   10. They are not offered to a Public Official without the prior written approval of the Company’s General Counsel.

   Specific red flags that may arise during the course of Employees’ work are set out in Annex to this Policy.

   2Encapsulate recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. Where it is inappropriate to decline the offer of a gift (such as when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the Company’s General Counsel, who will assess the circumstances.

   Gifts given and received in excess of £40 or $50 should always be disclosed to the Company’s General Counsel. Employees should seek the advice of the Company’s General Counsel concerning any uncertainty about the propriety of a gift, invitation, or hospitality.

   Kickbacks

   2Encapsulate prohibits offering, awarding, or accepting kickbacks. A kickback is a payment made to a person who facilitated a transaction or other act, where a portion of the profit or advantage obtained is ‘kicked back’ to that person. Kickbacks are typically made in exchange for an improper business favor or advantage.

   Political contributions and charitable donations

   Employees may not directly or indirectly use any Company funds or assets to make charitable donations, political contributions, or engage in or commission any lobbying on behalf of the Company without the prior written approval of the Company’s General Counsel.

   Employees must ensure that all charitable and political contributions are legal and ethical under the applicable laws and practices, and that they are not used to facilitate or conceal acts of bribery.

   6. Seeking advice and reporting concerns

   This section of the Policy covers 3 areas:

   • How to raise a concern.

   • What to do if you are a victim of bribery or corruption.

   • Protection.

   How to seek advice or raise a concern

   Employees who suspect that there is an instance of bribery or corruption occurring in relation to the Company are encouraged to raise their concerns as soon as possible through their manager or the Company’s General Counsel. If an Employee is uncertain whether an action or behavior constitutes bribery or corruption, that Employee should speak with their manager or the Company’s General Counsel.

   What to do if you are a victim of bribery or corruption

   Employees must tell the Company’s General Counsel as soon as possible if they are offered a bribe by anyone, are asked to make one, or if they have reason to suspect that they may be offered a bribe or asked to make a bribe in the near future.

   Employee Protection

   The Company will not tolerate retaliation or discrimination—including dismissal, disciplinary action or other unfavorable treatment—against any person who in good faith reports or seeks clarification about a suspected violation of this Policy, or against any person who refuses to carry out a request or action that they believe in good faith would violate this Policy or any applicable law.

   2Encapsulate will support any Employee who raises concerns in good faith under this Policy, even if investigation finds that they were mistaken. If an Employee believes they have been subjected to unjust treatment as a result of raising a concern or refusing to accept or make a bribe, they should inform their manager or the Company’s General Counsel immediately. Individuals who retaliate will be disciplined, which can include termination of employment.

   7. Training and communication

   As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities. The Company will provide anti-corruption training as part of the onboarding process for all new Employees. Certain Employees may also receive additional training on a periodic basis depending on the risk that they will face, or if they supervise individuals who may face, potential corruption risks in the course of their employment. It is the obligation of all Employees to undergo and comply with such training as instructed.

   This Policy and zero-tolerance attitude will be clearly communicated to all Third Parties at the outset of business relations and reiterated as appropriate thereafter.

   8. Record keeping

   Employees must declare and keep a written record of all gifts, invitations, and hospitality offered or accepted. These are subject to managerial review.

   All transactions involving Company assets shall be promptly and accurately recorded as required by the Company’s internal controls. These records must be made in reasonable detail, accurately and fairly reflecting the transactions and disposition of Company assets. There are to be no undisclosed or unrecorded funds or assets for any reason.

   The Company maintains a system of internal accounting controls to ensure the reliability and accuracy of its books and records and the proper recording of all transactions, and to ensure that the disposal of assets adheres to management’s general and specific instructions.

   9. Personal responsibility

   All Employees must ensure that they read, understand, and comply with this Policy and with any training or other anti-bribery and corruption information they are given.

   All Employees and those under the Company’s control are responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or give the impression of, a breach of this Policy.

   If an Employee has reason to believe or suspect that an instance of bribery or corruption in breach of this Policy has occurred or will occur in the future, that Employee must notify the Company’s General Counsel as soon as possible.

   The Company has the right to terminate a contractual relationship with an Employee if they breach this Policy. If an Employee breaches this Policy, they will face disciplinary action and could face dismissal for gross misconduct.

   Employees are responsible for ensuring that all accounts, invoices, memoranda and other documents and records relating to dealings with Third Parties are prepared and maintained with strict accuracy and sufficient detail. No accounts may be kept ‘off-book’.

   Employees must ensure all expense claims relating to gifts, invitations, and hospitality or expenses incurred in relation to Third Parties are submitted in accordance with the Company expenses policy and specifically record the reason for the expenditure.

   10. Monitoring and reviewing

   2Encapsulate’s General Counsel is responsible for monitoring the effectiveness of this Policy and will review its implementation, suitability, and adequacy on a regular basis. Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

   Any needed improvements will be implemented as soon as possible. Employees are encouraged to offer their feedback on this Policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Company’s General Counsel.

   2Encapsulate may amend this Policy at any time to improve its effectiveness at combatting bribery and corruption.

   September 2025

   ANNEX

   Bribery and Corruption Red Flags

   The following is a list of bribery and corruption red flags that may arise during the course of Employees’ work. A red flag does not necessarily mean that a Third Party is engaged in bribery or corruption but is a reason to subject the Third Party to greater scrutiny. The list is not intended to be exhaustive and is for illustrative purposes only.

   The Company applies a risk-based approach to screening Third Parties based on the red flags raised. If an Employee encounters any of these red flags while working for the Company, they must report them promptly to the Company’s General Counsel:

   1. A Third Party engages in, or has been accused of engaging in, improper business practices;

   2. A Third Party refuses to divulge adequate information during due diligence procedure;

   3. A Third Party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a ‘special relationship’ with Public Officials;

   4. A Third Party insists on receiving a commission or fee payment before committing to sign a contract with us or carrying out a government function or process for us;

   5. A Third Party requests payment in cash or cash equivalents and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

   6. A Third Party refuses to agree in contract to anti-corruption compliance terms;

   7. A Third Party is a Public Official or has a personal, family, business, or other close relationship with a Public Official;

   8. A Third Party requests that payment is made to a country or geographic location different from where the Third Party resides or conducts business;

   9. A transaction involves or takes place in a country with a reputation for bribery and corruption. For reference, please see the Transparency International Corruption Perception Index. https://www.transparency.org/en/cpi/2021;

   10. A Third Party makes large or frequent political contributions;

   11. A Third Party requests an unexpected additional fee or commission to ‘facilitate’ a service;

   12. A Third Party demands lavish gifts, invitations or hospitality before commencing or continuing contractual negotiations or provision of service;

   13. A Third Party requests a payment to ‘overlook’ alleged legal violations;

   14. A Third Party requests that you provide employment or some other advantage to a friend, relative, or associate;

   15. A Third Party requests that you make a political contribution or donation to the party or charity of their choice before agreeing to undertake a business relationship with 2Encapsulate;

   16. A Third Party provides a non-standard or customized invoice;

   17. A Third Party refuses to put terms agreed in writing;

   18. 2Encapsulate has been invoiced for a commission or fee payment that appears unduly large given the service stated to have been provided;

   19. A Third Party requests or requires the use of a specific Agent, intermediary, consultant, distributor or supplier, particularly one that is not typically used by or known to us; or

   20. You are offered an unusually generous gift or offered lavish hospitality by a Third Party.