1. STATEMENT OF ETHICS

• 1. Vela Ventures will act fairly and ethically wherever We do business. Our reputation is built on Our values as a company, the values of Our Representatives and Our collective commitment to acting with integrity throughout Our organisation.
• 2. Vela Ventures, its Group and its Directors condemn corruption and bribery in all forms and We will not tolerate it in Our business or in those We do business with. It is not a victimless crime, but can undermine values such as democracy, human rights, the rule of law, freedom of speech and free markets. Bribery and corruption also enable organised crime and terrorism.
• 3. This Policy sets out how Vela Ventures’s Representatives should behave and act when confronted by corruption and bribery. Vela Ventures and its Representatives will embrace this Policy and its values and make use of it in all aspects of Our work.
• 4. There are five key principles which will guide Vela Ventures and its Representatives in remaining vigilant to the risks of bribery and corruption:
  • 4.1. Honesty. We will act with honesty and in good faith in everything We do at work.
  • 4.2. Integrity. If something seems wrong, always report it. We will never allow Ourselves to be forced into doing something We know or suspect is wrong.
  • 4.3. Accountability. If any actions of Representatives or Vela Ventures break the law, the consequences may include a fine, imprisonment, or both. In addition, Vela Ventures
  • 4.4. Record keeping. Vela Ventures and its Representatives commit to accurate record keeping in relation to all payments, invoices and receipts. Keeping records of payments made and received, and what they relate to, contributes to transparency within Vela Ventures.
  • 4.5. Vigilance. Vela Ventures and its Representatives should be vigilant for, question and be prepared to challenge prices or services which don’t seem to correspond with reality or seem suspicious. For example, agents requesting excessively large fees or commissions for their work may be intending to pay bribes on Our behalf.
  • 4.6. Reporting. Vela Ventures and its Representatives commit to timely reporting of any suspicions or knowledge of breaches of Anti-Bribery Laws or this Policy. Reporting any potential bribery or corruption quickly will help investigations proceed in good time and may mitigate legal and regulatory consequences.