4.1 All forms of bribery, including (i) offer, (ii) promise, (iii) agree to pay, (iv) authorise payment of, (v) pay, (vi) give, (vii) accept, or (viii) solicit anything of value are prohibited. Promising to give a bribe / Kickback or agreeing to receive it before it has taken place is also a violation of this Policy. Lexim's employees should also avoid circumstances that even create the appearance of Bribery. Any breach of this Policy or anti-bribery regulations could result in disciplinary action, including termination of employment. Bribery, Kickback, and Facilitation Payments are prohibited when dealing with any person (individual and entities) both in the public or private sector.

4.2 It is strictly prohibited for Lexim or any members of its Board, staff, consultants or contractors, any group company, agent, business partner, contractor or supplier of Lexim to make any payments to a third party where there is any reason to believe that all or any part of such payment will go towards a bribe or otherwise facilitate any corruption.

4.3 Neither Lexim nor its employees may directly or indirectly offer, promise, authorise or pay anything of value to any person, whether a private individual, a representative of a government or corporate entity or any other person or entity, where the purpose is to improperly induce the recipient to take or to refrain from taking an action that would result in a Commercial Advantage to Lexim, its subsidiaries (if any) or any other party. These restrictions apply both directly as well as indirectly (e.g., offering, promising, authorising and paying anything of value to family members, close associates or favoured organisations of Government Officials or any other persons or entities (including those in the private sector) as well as charities or not-for-profit institutions that may be associated in any way or form to family members, close associates or favoured organisations of Government Officials or any other persons or entities when done with the purpose to unlawfully induce to make or abstain from a certain decision).

4.4 No employee or authorised representative may directly or indirectly seek, receive, or accept anything of value where the purpose is to improperly induce the employee or authorised representative to take or refrain from taking an action that would result in a Commercial Advantage to the person or entity providing anything of value, its subsidiaries, or any other party.

4.5 In coordination with the compliance team and using a risk-based approach, Lexim is responsible for establishing satisfactory due diligence and monitoring procedures for its representatives, consultants, distributors, resellers, vendors, suppliers, contractors, and all other respective business partners. Such due diligence procedures shall include a reasonable investigation into the business partners' background, reputation, and business capabilities. Lexim’s Outsourcing Policy details the procedure for the due diligence to be undertaken for all third-party service providers. All payments made by Lexim for services must be appropriate and justifiable for the

purpose of legitimate services provided.

4.6 Employees must be careful when agreeing on fees and payment terms with third parties, agents, brokers, distributors, and other business partners, as some types of compensation arrangements can be used or viewed as Bribery. The deliverables that are to be provided for the agreed upon fees must be clearly defined and documented. For example, descriptions of deliverables and payments to agents or consultants must be clear and accurate.

4.7 Payments that are vague or outside of regular payment practices or standards can be a sign that some payments are being used improperly.

4.8 Commissions, discounts, bonuses, and other similar payments should be carried out in accordance with adequately established accounting and finance procedures and criteria. Employees must never make any side payments or other unauthorised use of Lexim's funds. All forms of compensation must be properly approved, documented, and processed to accurately reflect the nature of transactions and free from any inaccurate, false, or deceptive information or data. This is important because for a bribe to be paid, the funds must be taken from our company; if we can stop the flow of corrupt payments, we can prevent acts of Bribery in many situations. Any requests for additional bonuses, discounts or other payments must be properly authorised and documented in accordance with Lexim's finance manual.

4.9 All systems for tracking commissions, discounts, and other payments must be properly used in line with established and approved procedures.

4.10 To summarise the general principles of forbidden forms of bribery and corruption, it is prohibited for any members of the Board and all staff to:

(a) give, promise to give, or offer payment, gifts, or hospitality to a third party or otherwise permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received or to reward a Commercial Advantage already given. Employees must refuse to accept or make the payment from or to a third party, explain Lexim's Policy against accepting or making such payments, and clarify that the refusal is final and nonnegotiable. In case an employee encounters any difficulty making a refusal, they should seek assistance from the compliance team. Immediate reporting is essential.

(b) give, promise to give, or offer a payment, gift, or hospitality to a third party to facilitate or expedite a routine procedure;

(c) accept hospitality from a third party if it knows or suspects that such payment, gift, or hospitality is offered or provided with an expectation that a Commercial Advantage will be provided by Lexim in return;

(d) engage in any activity that might lead to a breach of the anti-bribery and corruption rules and guidelines of any applicable international or local laws.

(e) threaten, retaliate against, or otherwise penalise any member of the Board or staff who has refused to commit a bribery offence or who has raised concerns about actual or suspected bribery or corruption. Lexim maintains a zero-tolerance approach to any form of retaliation, and any such conduct will be treated as a serious disciplinary matter.

4.11 Avoiding and Managing Conflicts of Interest

(a) In some situations, engaging companies and individuals with a personal relationship with an employee on Lexim's behalf can appear or constitute a Conflict of Interest. Should a Conflict of Interest arise or an employee becomes aware of its existence, the employee must refrain from making any decisions while the Conflict of Interest exists and must bring the matter to the attention of their manager, the compliance team, or the human resources department.

(b) Employees and third parties shall avoid situations that may create a Conflict of Interest between Lexim and themselves.

(c) Employees and third parties shall never take advantage of their relationship with Lexim for personal gain or any other goal that may impact their judgement, loyalty, or objectivity.

(d) Please refer to Lexim's Conflicts of Interest Policy for more detailed guidance on this matter.

4.12 Gifts, Travel and Entertainment

(a) Bona fide hospitality and promotional, or other business expenditures such as gifts, travel or entertainment expenditures seeking to establish cordial relations, is recognised as an important part of doing business. This Policy does not prohibit reasonable and proportionate gifts, hospitality, entertainment and other business expenditures when intended for genuine purposes and of minimal value. The following are some important rules of what is acceptable (for more details, see Section 5 of this Policy):

i. It is bona-fide and made in the normal course of business and does not create the appearance (or an implied obligation) that the gift giver is entitled to preferential treatment, an award of business, better prices, etc.

ii. Gifts, meals, entertainment, and travel should not be lavish, extravagant or out of line with country or industry norms.

iii. Frequent gifts to the same individual/business, even if inexpensive, are inappropriate.

iv. Gifts, meals, entertainment, and travel should have a justifiable business purpose.

v. Gifts must be given openly, at an appropriate time and circumstance—not secretly or through a third party.

vi. Gifts, entertainment and hospitality should comply with prevalent laws and regulations.

vii. Lexim's employees should be present at all meals and entertainment activities and exercise good judgment in choosing entertainment that does not jeopardise the company's reputation or interests.

viii. Lexim should pay for meals, entertainment, and/or travel only for invitees whose participation is directly related to and necessary for Lexim's legitimate business purposes.

ix. Gifts should only be accepted when they align with the principles of this Policy and any applicable laws or regulations.

x. The acceptance of gifts should not influence or appear to influence the business decisions or actions of Lexim employees.

(b) Examples of Acceptable Gifts

i. Promotional items with a company logo of nominal value, such as pens, keychains, or notepads.

ii. Meals or refreshments offered during business meetings, conferences, or training events.

iii. Tokens of appreciation, such as small gift baskets or personalised items, with a value within the acceptable limit.

iv. Gifts provided as part of a customary business practice in the local culture, within the limits defined by this policy and local laws. If you have any doubts about whether a gift, meal, entertainment or travel expense is appropriate, the best course of action is to seek guidance from the compliance team.

(c) Interaction with Government Officials

i. Lexim seeks transparent and cooperative relationships with governments.

ii. Lexim, its employees and associated persons shall not offer or give anything of value with the intention to influence a government official to obtain or retain business or a Commercial Advantage.

(d) Facilitation Payments

i. Lexim prohibits Facilitation Payments which seek to expedite or secure the performance of a particular routine governmental action by a government official.

(e) Agents

i. Agents are individuals or entities paid by Lexim who negotiate with third parties on Lexim's behalf. Lexim is committed to promoting compliance with its ABC Policy by all third parties acting on Lexim's behalf.

ii. Lexim can be held liable for actions by third parties. The acts of the agents will be considered the acts of Lexim. As such, all third parties should be made aware of the terms of this Policy and the obligation to comply with it. Employees must not partner with any third party who is suspected of or known for engaging in bribery.

iii. Appropriate due diligence should be undertaken before any third parties are engaged. The level of due diligence will vary depending on the circumstances. For "red flags" involving third parties, refer to Appendix B of this Policy.

(f) Charitable Donations

i. Lexim believes in contributing to the communities in which it does business. While charitable contributions are encouraged, Lexim only makes charitable donations that are legal and ethical under local laws and practices and within the organisation's corporate governance framework.

ii. Lexim employees should ensure that the contribution is not an indirect way of conferring a personal benefit on a government official or related party and that the contribution is not in exchange for a purchasing or other decisions affecting Lexim's interests. Employees and third parties should not make payments, whether in cash or in kind, to political candidates, political officials or political parties for the purpose of obtaining, retaining or directing business to Lexim.