ANTI-CORRUPTION POLICY AND CODE OF ETHICS

ANTI-CORRUPTION POLICY AND CODE OF ETHICS of FUNKY PLUS Ltd.

To prevent corruption, FUNKY PLUS Ltd. conducts all its activities in accordance with the applicable legislation in all areas of its operations and is committed to adhering to the following principles outlined in the Code of Ethics and Conduct.

1. Compliance with the Law and Ethical Values.
   Comply with applicable laws and internal regulations by acting in accordance with the values and Code of Ethics and Conduct of FUNKY PLUS Ltd.

2. Zero Tolerance for Bribery and Corrupt Practices:
   2.1. Zero Tolerance: Promote a culture of combating corruption and bribery by prohibiting influence over third parties’ decisions for the purpose of gaining advantages, encouraging favorable treatment, or securing benefits for the company.
   2.2. Giving and Receiving Gifts and Invitations on Behalf of the Company:
   Avoid giving or unjustified acceptance—directly or indirectly—of commissions, payments, or gifts that imply any form of benefit.

3. Prevention of Money Laundering and Transparent Communication.
   Avoid illicit payments and receipts, monitor the source and destination of funds to comply with money laundering and anti-terrorism financing regulations.

4. Transparent Relations with the Community.
   Avoid making improper payments, such as facilitation payments to public officials, donations used to disguise illegal payments, or direct or indirect financing of political parties, representatives, or candidates.

5. Conflict of Interest.
   Act loyally and protect the interests of FUNKY PLUS Ltd. by avoiding situations that may lead to conflicts between personal interests and those of the company, including activities or operations outside the group or personal interests or transactions economically connected to the company. If a conflict of interest arises, it must be reported through the designated channels.

6. Monitoring of Assets and Data Confidentiality.
   Comply with all applicable regulations related to information security and data protection by following and enforcing the company’s data protection measures concerning customer data and sensitive information. This ensures the prevention of unauthorized access by external parties or employees to information and data for which they are not authorized.

7. Rigorous Control, Reliability, and Transparency.
   Ensure accurate and adequate recording of all actions, operations, and transactions of the company in the designated books and records, in accordance with the principles of control, reliability, and transparency of information.

8. Extending Commitment to Business Partners.
   Ensure that FUNKY PLUS Ltd. establishes business relationships only with partners who have demonstrated ethical behavior and a high level of commitment, thereby ensuring stable business relationships and avoiding any lack of integrity among individuals or entities the company works with.

9. Promotion of Continuous Ethics and Compliance Training for All Employees.
   Pay special attention to combating fraud and corruption by providing the necessary human and material resources for the effective dissemination of this policy and the implementation of means to prevent and detect unlawful acts. If any employee has evidence or suspicions of any form of fraud or corruption, they must report it immediately so that, under proper oversight, the corporate compliance officer can inform the Manager and initiate the appropriate investigation and clarification of the facts.

Issued: 01-02-2024