Anti-Bribery and Corruption Policy

Klarity Health (“Klarity”) is committed to conducting business ethically and with integrity. Bribery and corruption are illegal, harmful and fundamentally at odds with our values.

This policy applies to all employees, directors, contractors, agents and any other person acting on Klarity’s behalf, anywhere in the world. It has been prepared with reference to the UK Bribery Act 2010 (“the Act”).

Bribery is the offering, promising, giving, accepting or soliciting of an advantage (financial or otherwise) as an inducement for action that is improper, illegal or a breach of trust. Both active bribery (offering or paying) and passive bribery (requesting or receiving) are criminal offences under the Act.

Under the Act, Klarity can also be held liable if a person associated with the company bribes another person to obtain or retain business for Klarity, even without the knowledge of directors.

No one covered by this policy may:

• Offer, promise or give a bribe to any person, including a public official.

• Request, agree to receive or accept a bribe.

• Facilitate or conceal bribery by a third party.

• Engage in any conduct that could constitute bribery of a foreign public official.

• Threaten or retaliate against anyone who refuses to pay or receive a bribe.

Reasonable, proportionate gifts and hospitality are a legitimate part of business relationships. However, they must never be used to gain an improper advantage. The following principles apply:

• All gifts and hospitality given or received with a value above £50 must be recorded in the company’s gifts register.

• Gifts of cash or cash equivalents (e.g. vouchers) must not be given to or received from clients, suppliers or officials under any circumstances.

• Hospitality must be proportionate, transparent and incidental to a legitimate business meeting.

• You must never offer gifts or hospitality to a public official without prior approval from a director.

Klarity does not make political donations. Any charitable contributions made on behalf of the company must be approved by a director and must not be used as a mechanism for making improper payments.

Before engaging agents, intermediaries, consultants or other third parties who will interact with clients or officials on Klarity’s behalf, reasonable due diligence should be conducted to assess bribery risk. Contracts with such parties should include appropriate anti-bribery representations and termination rights.

Klarity maintains accurate financial records and internal controls. Payments must be properly authorised and documented. No false or misleading entries may be made in financial records for any reason, including to conceal a bribe.

If you suspect that bribery or corruption has occurred, is occurring or is being planned, you must report it immediately. You can:

• Speak directly with a company director.

• Use the confidential reporting mechanism in the Whistleblower Policy.

Klarity will investigate all reports promptly and in confidence. No person who raises a genuine concern in good faith will face any detriment.

Any breach of this policy is a serious disciplinary matter and may result in summary dismissal. Where the breach constitutes a criminal offence, Klarity will cooperate fully with law enforcement authorities. Individuals found guilty of bribery offences under the Act can face up to ten years’ imprisonment.

This policy is reviewed annually. Any questions regarding its application should be directed to a company director.