ANTI-BRIBERY AND CORRUPTION POLICY STATEMENT

Updated 02/06/2023

Dukka Limited (“Company”) is committed to conducting business in an ethical and honest manner. We believe that ethical conduct is essential to our success and to the success of our customers and partners. We expect all employees and individuals acting on our behalf to uphold our high standards of ethical conduct.

Our organization is dedicated to conducting business with transparency and ethics at the forefront. We firmly believe that bribery and corruption exert negative influences on business operations, eroding good governance and distorting fair market practices.

We maintain a zero-tolerance policy towards all forms of bribery, whether they occur directly or indirectly, involving our employees, officers, agents, consultants, or any individuals or entities acting on our behalf.

Both the board and senior management are deeply committed to establishing and upholding robust systems that effectively prevent and eradicate bribery, aligning with the provisions of the Bribery Act 2010.

The Company and its subsidiary companies have introduced comprehensive policies aimed at combating bribery, corruption, as well as guidelines concerning gifts and corporate hospitality. These policies explicitly define the Company's stance on preventing and condemning bribery and corruption. They are applicable to all employees who are obligated to acquaint themselves with these policies and adhere to them.

A bribe refers to any form of financial advantage or reward, whether provided directly or indirectly, to an individual or company, with the intention of inducing or influencing them to carry out public or corporate functions improperly.

The Company strictly prohibits its employees and individuals representing or acting on its behalf from engaging in any form of bribery, solicitation, or receipt of unauthorized payments. To combat bribery effectively, the Company acknowledges and accepts transparent, proportionate, reasonable, and legitimate hospitality and promotional expenses, whether given or received.

Any violation of these policies by an employee will be considered as grounds for disciplinary action. It is important for employees and other individuals representing the Company to be aware that bribery is a criminal offense punishable by up to 10 years of imprisonment and/or an unlimited fine for individuals, as well as an unlimited fine for the Company.

Furthermore, the Company has adopted a policy of not engaging in business relationships with service providers, agents, or representatives who do not align with appropriate anti-bribery and corruption objectives. The effectiveness of the Company's anti-bribery and corruption efforts relies on the active involvement of all employees and individuals representing the Company. It is essential that everyone plays their role in preventing bribery. Therefore, the Company strongly encourages all employees and those acting on its behalf to promptly report any suspected incidents of bribery, following the procedures outlined in the Policies. In the case of third parties, the reports should be made to the Company Secretary. The Company assures full support and protection to individuals who make such reports in good faith.