Ethical Business

# Ethical Business Practices Policy

Academia Park Ltd. (hereinafter referred to as "we", "us" or "our") is committed to conducting our business with the highest standards of ethics, integrity, and compliance. This policy outlines our dedication to responsible business practices and adherence to all applicable laws and regulations.

## 1. Policy Owner

Academia Park Ltd.

Registered Address: Queen Elizabeth Olympic Park, Here East, Plexal, London, E20 3BS United Kingdom

Company Registration Number: 10560940

Email: london@academiapark.co.uk

## 2. Areas of Ethical Commitment

We are committed to ethical practices in the following areas:

a. Anti-Bribery and Corruption

b. Gifts and Entertainment

c. Sanctions Compliance

d. Conflicts of Interest

e. Whistleblowing

f. Third Party Risk Management

g. Modern Slavery and Child Labour

## 3. Policy Details

### 3.1 Anti-Bribery and Corruption

We have a zero-tolerance approach to bribery and corruption in all its forms. Our employees and business partners are prohibited from offering, promising, giving, requesting, or accepting any bribes or improper payments.

### 3.2 Gifts and Entertainment

We recognize that appropriate gifts and entertainment can be part of building business relationships. However, we have strict guidelines to ensure that such practices never influence business decisions improperly or create the appearance of impropriety.

### 3.3 Sanctions Compliance

We are committed to complying with all applicable international trade sanctions. We have robust procedures in place to ensure we do not engage in transactions with sanctioned entities or individuals.

### 3.4 Conflicts of Interest

We require all employees and business partners to disclose any potential conflicts of interest. We have processes in place to manage these conflicts fairly and transparently.

### 3.5 Whistleblowing

We encourage a speak-up culture. We have established secure channels for reporting concerns about potential misconduct, and we strictly prohibit retaliation against anyone who raises concerns in good faith.

### 3.6 Third Party Risk Management

We carefully select and monitor our business partners. We conduct due diligence to ensure they share our commitment to ethical business practices and comply with all relevant laws and regulations.

### 3.7 Modern Slavery and Child Labour

We are committed to combating modern slavery and child labour in all its forms. We have strict policies and procedures to ensure that our operations and supply chains are free from these practices.

## 4. Implementation and Training

We regularly review and update these policies to ensure they remain effective and aligned with global best practices. All our employees receive regular training on these policies, and we expect our business partners to adhere to similar standards.

## 5. Compliance Monitoring

We have implemented appropriate measures to monitor compliance with this policy. This includes regular audits, risk assessments, and reviews of our business practices and those of our partners.

## 6. Reporting Violations

If you suspect any violation of this policy, please report it immediately to our compliance team at london@academiapark.co.uk. All reports will be treated confidentially and investigated promptly.

## 7. Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, up to and including termination of employment or business relationships. In some cases, violations may also lead to legal action.

## 8. Changes to this Policy

We may update this policy from time to time. Any changes will be communicated to all employees and relevant business partners.

## 9. Contact Us

If you have any questions about this policy or our ethical practices, please contact our compliance team at london@academiapark.co.uk.

This ethical business practices policy was last updated on 1 April 2024.