ANTI-BRIBERY & CORRUPTION

ZEDRA’s position on anti-bribery and corruption

Pursuant to the relevant law, regulations, codes of practice and/or regulatory guidance regarding anti-bribery and anti-corruption applicable in each of ZEDRA’s jurisdictions, ZEDRA has in place an anti-bribery and anti-corruption policy (the Policy) supported, where relevant, by appropriate procedures. The Policy prohibits (inter alia) the making, offering or promising to make, requesting, accepting or receiving a payment (including any service, gift or entertainment) for any improper purpose or business advantage. The Policy applies to all employees of ZEDRA and its group companies and all business undertaken and structures administered by those entities.

ZEDRA is committed to achieving the highest standards of ethical conduct and to ensuring that its employees and external parties who may provide services on its behalf, act in compliance with applicable legislation. This includes compliance with all laws, domestic and foreign, prohibiting improper payments or inducements to any person, including Public Officials (as defined under applicable law).

Before any transactions occur or services are provided, ZEDRA will require confirmation of awareness of the applicable law from all clients (by means of an Engagement Letter (or equivalent)) and relevant third parties, such as consultants, those holding power of attorneys and those to whom ZEDRA has outsourced or delegated a function (by means of an appropriate declaration), together with confirmation that, where relevant, they have in place appropriate anti-bribery and anti-corruption policies and procedures of their own; or otherwise conduct themselves in such a manner as to adhere to the applicable law and this policy statement. Where deemed appropriate, ZEDRA will also carry out additional due diligence. All payments must be made on clear payment terms (including clarity in relation to what is being paid for).

ZEDRA has procedures in place requiring the reporting of any knowledge or suspicion that any client, relevant third party or employee is involved in any way in bribery or corruption.

Modern Slavery Statement

AIMING GREEN

WORLD HEARTBEAT MUSIC ACADEMY