Vika Group Anti-Corruption Policy

Vika Group is committed to conducting all of its business activities with integrity and in full compliance with applicable anti-corruption and anti-bribery laws, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and all applicable local laws in the DRC, Zambia, Angola, and any other jurisdiction in which the Group operates.

This policy applies to all directors, officers, employees, consultants, agents, and any third parties acting on behalf of Vika Group or any of its subsidiaries and operating companies.

Vika Group maintains a strict zero-tolerance approach to bribery and corruption in all its forms. No Vika Group personnel or associated party may, directly or indirectly:

• Offer, promise, give, request, agree to receive, or accept any bribe, kickback, or improper payment — whether in cash or in any other form of value;
• Make or receive facilitation payments to or from any government official or private party;
• Use a third party as a conduit for any payment that would itself be prohibited under this policy;
• Engage in any conduct that constitutes corruption under applicable law.

This prohibition applies regardless of local custom, competitive pressure, or the perceived necessity of the payment to secure or retain business.

Vika Group recognises that reasonable and proportionate gifts and hospitality can be a legitimate part of building business relationships. However, all gifts, hospitality, and business expenses must be:

• Modest in value and appropriate to the business relationship;
• Transparent and accurately recorded in the Group's books and records;
• Not offered or received with any expectation of a business advantage in return;
• Consistent with applicable law and the recipient's own organisation's policies.

Any gift or hospitality with a value exceeding USD 100 must be pre-approved by senior management and recorded in the Group's gifts and hospitality register.

Vika Group operates in jurisdictions where interactions with government officials are frequent and necessary. All such interactions must be conducted with particular care. Personnel must:

• Never offer anything of value to a government official to influence an official act or decision;
• Ensure that all government fees, taxes, and levies are paid through official channels and properly documented;
• Obtain prior written approval from senior management before engaging any agent or intermediary to interact with government officials on the Group's behalf;
• Conduct enhanced due diligence on all third parties who interact with government officials on the Group's behalf.

Vika Group recognises that it may be held liable for corrupt acts committed by third parties acting on its behalf. The Group therefore applies risk-based due diligence to all significant business partners, agents, consultants, and contractors, including:

• Background checks and integrity screening prior to engagement;
• Review of ownership structures and identification of beneficial owners;
• Assessment of anti-corruption compliance programmes;
• Contractual anti-corruption representations and warranties;
• Ongoing monitoring of high-risk relationships.

All Vika Group entities must maintain accurate and complete books and records that fairly reflect all transactions and dispositions of assets. No false, misleading, or incomplete entries may be made in the Group's financial records for any reason. The Group maintains internal controls designed to prevent and detect corrupt payments.

All Vika Group personnel are required to report any known or suspected violation of this policy promptly. Reports may be made to the Chief Executive Officer or, where the concern involves senior management, directly to the Board. Vika Group prohibits retaliation against any person who reports a concern in good faith. All reports will be treated confidentially to the extent practicable.

Violation of this policy may result in disciplinary action up to and including termination of employment or engagement, and may be referred to relevant law enforcement authorities. Vika Group will not indemnify any individual for fines or penalties imposed as a result of corrupt conduct.

Vika Group provides regular anti-corruption training to all personnel and ensures that this policy is communicated to all relevant third parties. The policy is reviewed annually and updated as required to reflect changes in applicable law and best practice.