BUSINESS

Last updated: October 12, 2026

1. Purpose and Scope

This Policy sets out the standards of business conduct expected of Veritant Advisory Limited (“Veritant,” “we,” “us,” or “our”), including its Founder, consultants, advisors and anyone acting on its behalf. It applies to all Veritant engagements and is supplemented by any specific integrity, anti-corruption or sanctions requirements that apply to a particular client or engagement.

2. Anti-Bribery and Corruption

Veritant has zero tolerance for bribery, corruption, fraud and facilitation payments. No person acting for or on behalf of Veritant may offer, promise, give, request or accept anything of value to improperly influence a business decision, obtain or retain business, or secure an improper advantage. This includes cash, gifts, hospitality, favours and other benefits. Veritant complies with applicable UAE law and, where relevant to an engagement, applicable international anti-corruption requirements.

3. Gifts, Hospitality and Facilitation Payments

Gifts and hospitality must be reasonable, occasional and appropriate to the circumstances and must never be intended to improperly influence a decision. Cash and cash-equivalent gifts are not permitted. Veritant does not make or permit facilitation payments. Any request for such a payment should be reported promptly to the Founder & CEO.

4. Conflicts of Interest

Veritant works with a network of senior advisors who may have current or previous relationships with development finance institutions, banks, investors and other organisations that may also be clients or counterparties. Before accepting an engagement, advisors must disclose any relationship that could create an actual or potential conflict. Conflicts will be assessed and, where necessary, managed through appropriate measures, including recusal from a particular engagement. Veritant’s independence commitments are set out in Section 5.

5. Independence

Veritant provides advice through the lens of sustainable finance. It does not provide investment advisory services for commercial purposes. Veritant does not lend, invest, arrange or place capital, or build or operate physical assets. Veritant advises on how financing should be structured to meet sustainability requirements. It does not itself structure, arrange or execute the financing.

Veritant’s fees are fixed or time-based and do not depend on whether a transaction closes or financing is secured. Veritant does not accept success fees, finder’s fees, commissions or other payments that depend on the outcome of a transaction it has reviewed or advised on. Where Veritant or an advisor has a financial interest in an outcome, or has advised another party to the same transaction, this is disclosed to the client before the engagement. Where a conflict cannot be managed, Veritant will decline or withdraw from the engagement.

Veritant independently verifies information to help de-risk investments and portfolios. Whether financing can be accessed also depends on factors outside Veritant’s control, including the commercial feasibility of the investment, and Veritant does not commit to a financing outcome. This Section applies to all persons acting for Veritant, including consultants and network advisors.

6. Sanctions and Client Due Diligence

Before entering into a new engagement, Veritant conducts appropriate checks on prospective clients and relevant counterparties, including sanctions screening where appropriate. Depending on the engagement, this may include checks against relevant UN, US, EU and UK sanctions lists and confirmation of the identity and ownership of corporate clients. Veritant will not knowingly undertake an engagement that would breach applicable sanctions or other legal requirements.

7. Confidentiality and Non-Public Information

Veritant’s work may involve confidential, commercially sensitive or material non-public information. Such information must be kept confidential, used only for the relevant engagement and not disclosed without authorisation. No person acting for Veritant may use material non-public information obtained through a Veritant engagement for personal benefit or to trade, or encourage another person to trade, in securities.

8. Professional Conduct and Equal Opportunity

Veritant is committed to a professional working environment based on respect, equal opportunity and fair treatment. Discrimination, harassment, bullying and retaliation are not tolerated.

9. Client Integrity Requirements

Where a client or funder has specific integrity, anti-corruption, sanctions or other compliance requirements, including requirements applicable to development finance institutions or multilateral development banks, Veritant and the relevant advisors will comply with those requirements to the extent applicable to the engagement.

10. Reporting Concerns

Anyone working with or for Veritant who has a concern about conduct that may breach this Policy is encouraged to raise it with the Founder & CEO at tmansour@veritantadvisory.com. Concerns relating to the Founder & CEO may be raised at info@veritantadvisory.com. Concerns raised in good faith will not result in retaliation.

11. Review and Contact

Veritant will review this Policy periodically and update it as the business and applicable requirements develop.