Corporate Fight Corruption Policy

Anti-Corruption Compliance Program

Apta Solutions & Partners SL and its subsidiaries (Tricise Iberia SL, Tricise SAS, and Tricise SRL), are committed to conducting business with integrity, transparency, and in full compliance with all applicable anti-corruption laws and regulations. Corruption, bribery, and any form of unethical conduct are strictly prohibited in all company activities, both in Spain and internationally.

This program applies to all employees, managers, directors, contractors, suppliers, and business partners of Apta Solutions & Partners and its subsidiaries.

3. Principles and Commitments

a) Zero Tolerance: Apta Solutions & Partners maintains a zero-tolerance policy towards any form of corruption, bribery, or facilitation payments.

b) Compliance with Laws: All activities must comply with local, national, and international anti-corruption laws, including but not limited to the Spanish Criminal Code, UK Bribery Act, and US Foreign Corrupt Practices Act (FCPA).

c) Gifts and Hospitality: Employees must not offer, give, solicit, or accept gifts, hospitality, or other advantages that could improperly influence business decisions or create a conflict of interest.

d) Third Parties Due diligence must be conducted before engaging with third parties (suppliers, agents, consultants, etc.) to ensure they adhere to anti-corruption standards.

e) Accurate Record-Keeping: All transactions must be accurately recorded in the company’s books and records. False, misleading, or incomplete entries are strictly prohibited.

f) Reporting and Whistleblowing: Employees are encouraged and required to report any suspected or actual violations of this policy through established confidential channels. Retaliation against whistleblowers is strictly prohibited.

g) Training and Awareness: Regular training sessions will be provided to all employees and relevant third parties to ensure understanding and compliance with anti-corruption requirements.

h) Monitoring and Review: The compliance program will be periodically reviewed and updated to reflect changes in laws, regulations, and business operations.

4. Responsibilities

Management: Responsible for promoting a culture of integrity and ensuring the implementation of this program.

Compliance Officer: Oversees the anti-corruption program, provides guidance, and investigates potential breaches.

All Employees: Must comply with this policy and participate in training.

5. Disciplinary Measures

Violations of this program may result in disciplinary action, including termination of employment or contract, and may lead to civil or criminal penalties.

6. Approval and Communication

This policy is approved by the Management Board and the Compliance Officer. It is communicated to all employees and made available to stakeholders.

Valencia, October 2025

Signed:  Management Board