Anti Bribery and Anti Corruption Policy

1. Introduction

UFL is committed to conducting all business activities with integrity, transparency, and the highest ethical standards. The Company has a zero-tolerance approach to bribery and corruption in any form and is committed to complying with all applicable anti-bribery and anti-corruption laws and regulations.

UFL recognises that involvement in bribery or corruption, whether direct or indirect, can expose the Company and individuals to criminal liability, financial penalties, reputational damage, and loss of stakeholder trust.

The purpose of this Policy is to:

• Establish clear standards of conduct regarding bribery and corruption.
• Ensure that all employees, directors, contractors, consultants, agents, and other persons acting on behalf of UFL understand their responsibilities.
• Promote a culture of integrity and ethical business practices.
• Encourage the reporting of suspected bribery or corruption through appropriate channels.
• Ensure all allegations of bribery or corruption are investigated promptly and thoroughly.
• Take appropriate disciplinary and corrective action where breaches of this Policy occur.

All employees and representatives of UFL are expected to comply with this Policy at all times.

2. Scope

This Policy applies to:

• All directors, officers, and employees of UFL.
• Temporary workers, contractors, consultants, and agency staff.
• Agents, intermediaries, suppliers, business partners, and any third parties acting on behalf of UFL.

Compliance with this Policy is a condition of employment and engagement with UFL.

3. Definitions

Bribery

Bribery is the offering, promising, giving, requesting, agreeing to receive, or accepting of any financial or other advantage with the intention of influencing a person to perform their duties improperly or to obtain or retain a business or personal advantage.

Corruption

Corruption is the abuse of entrusted power, position, or authority for private gain.

4. Prohibited Conduct

UFL strictly prohibits:

• Offering, giving, soliciting, or accepting bribes of any kind.
• Making payments or providing benefits intended to improperly influence business decisions.
• Using third parties to carry out actions that would be prohibited if undertaken directly by UFL.
• Offering or accepting kickbacks, secret commissions, or other improper incentives.
• Providing anything of value to secure an unfair business, contractual, regulatory, or personal advantage.

No employee or representative of UFL may:

1. Gain any commercial, contractual, or regulatory advantage through unethical means.
2. Obtain any personal benefit, financial or otherwise, for themselves or any connected person.
3. Induce or reward the improper performance of any public, business, or employment-related function.

5. Facilitation Payments

Facilitation payments are unofficial payments made to secure or expedite routine governmental or administrative actions to which a person is already entitled.

Facilitation payments are prohibited by UFL and must not be offered, promised, made, requested, or accepted under any circumstances, unless there is an immediate threat to an individual’s health, safety, or wellbeing. Any such incident must be reported to management as soon as reasonably practicable.

6. Gifts and Hospitality

UFL recognises that reasonable and proportionate gifts and hospitality may form part of normal business relationships.

However, gifts, hospitality, entertainment, or other benefits must:

• Be reasonable, proportionate, and appropriate.
• Be given openly and transparently.
• Have a legitimate business purpose.
• Comply with applicable laws and regulations.
• Not create, or appear to create, an obligation or expectation of favourable treatment.
• Be accurately recorded in the Company’s books and records.

The following are prohibited:

• Cash gifts or cash equivalents.
• Excessive, lavish, or frequent hospitality.
• Gifts or hospitality intended to influence a business decision.
• Gifts or hospitality provided during procurement, tender, or contract award processes where a conflict may arise.

Employees should seek guidance from management where there is any uncertainty regarding the appropriateness of a gift or hospitality.

7. Charitable Donations and Sponsorships

UFL supports legitimate charitable and community initiatives. All charitable donations and sponsorships must:

• Be lawful and ethical.
• Be approved in accordance with Company procedures.
• Not be used as a means of obtaining an improper business advantage.
• Be properly documented and recorded.

8. Political Contributions

UFL does not make political contributions on behalf of the Company unless expressly approved by the Board and permitted by applicable law.

Employees must not use Company funds, resources, or assets to support political parties, candidates, or campaigns without prior authorisation.

9. Reporting Concerns

All employees and representatives of UFL have a responsibility to report any suspected or actual bribery, corruption, or other unethical conduct.

Reports should be made to:

• A line manager;
• A director; or
• Any designated whistleblowing or reporting channel.

Reports made in good faith will be treated confidentially wherever possible.

UFL will not tolerate retaliation, victimisation, or adverse treatment against any person who raises a genuine concern under this Policy.

10. Investigation and Enforcement

Any suspected breach of this Policy will be investigated promptly, fairly, and confidentially.

Where misconduct is established, UFL may take appropriate action, including:

• Disciplinary action up to and including dismissal;
• Termination of contracts with third parties;
• Referral to law enforcement or regulatory authorities where appropriate.

11. Record Keeping

UFL will maintain accurate books, records, and financial controls to ensure that all transactions are properly authorised, recorded, and monitored.

No undisclosed, unrecorded, or misleading accounts or transactions are permitted.

12. Training and Awareness

UFL will provide appropriate anti-bribery and anti-corruption training and guidance to employees and relevant third parties as necessary.

Employees are expected to familiarise themselves with this Policy and complete any required training.

13. Monitoring and Review

The Board is responsible for overseeing the implementation and effectiveness of this Policy.

This Policy will be reviewed annually, or sooner where required by changes in legislation, regulation, or business operations, to ensure it remains effective and up to date.

June 2026