CUDO Ventures Limited

Version dated: 11 December 2025

Ethics policy

Purpose

This policy sets out our organization’s commitment to conducting business ethically, responsibly, and in full compliance with UK law. It provides a framework for expected standards of behaviour, decision-making, and accountability. By embedding ethical principles into our culture, we aim to build trust with employees, customers, suppliers, regulators, and the wider community.

Scope

This policy applies to:

  • All employees, contractors, agency workers, and temporary staff.
  • All suppliers, partners, consultants, and third parties engaged with our organization.
  • All business activities conducted in the UK and internationally, regardless of location or function.

Principles of ethical conduct:

Integrity and honesty

  • Employees must act with honesty, fairness, and transparency in all business dealings.
  • Conflicts of interest must be declared and managed appropriately (e.g., personal relationships with suppliers).
  • Fraud, corruption, or deception will not be tolerated under any circumstances. Please refer to our anti-corruption & bribery policy for further detail.
  • All financial reporting must be accurate, complete, and compliant with accounting standards.

Respect for people

  • We are committed to diversity, equity, and inclusion, ensuring equal opportunities for all.
  • Harassment, bullying, or discrimination of any kind is prohibited.
  • We respect human rights and uphold fair labour practices, including freedom of association and fair pay.
  • We promote a culture of dignity, respect, and collaboration in the workplace.

Anti-bribery and corruption

  • We maintain a zero-tolerance approach to bribery and corruption.
  • Employees must not offer, give, solicit, or accept bribes or improper advantages.
  • Hospitality and gifts must be proportionate, transparent, and recorded in line with company policy.
  • Facilitation payments (small payments to speed up routine processes) are strictly prohibited.

Please refer to our anti-corruption & bribery policy for further detail.

Confidentiality and data protection

  • Employees must protect confidential information, including trade secrets, IP, client data, and employee records.
  • Personal data must be handled lawfully, fairly, and securely, in line with UK GDPR.
  • Breaches of confidentiality or data protection obligations will be investigated and may result in disciplinary action.
  • Cybersecurity awareness training will be provided to all staff.

Environmental responsibility

  • We are committed to minimising our environmental impact.
  • Employees should act responsibly in relation to energy use, waste reduction, and sustainable practices.
  • We will comply with environmental legislation and seek opportunities to improve sustainability.

Fair competition

  • We support free and fair competition and comply with UK competition law.
  • Anti-competitive behaviour, including collusion, price-fixing, or abuse of market position, is prohibited.
  • Employees must avoid practices that could damage the integrity of markets or mislead customers.

Responsible use of company resources

  • Company assets, including IT systems, vehicles, and funds, must be used responsibly and for legitimate business purposes.
  • Misuse of resources, including theft, fraud, or unauthorised personal use, is prohibited.
  • Intellectual property must be respected and protected.

Responsibilities

  • Board and Senior Management: Ensure ethical standards are embedded in strategy, culture, and governance.
  • Managers: Lead by example, communicate expectations, and ensure teams understand and comply with this policy.
  • Employees: Act in line with this policy, complete required training, and raise concerns if they witness unethical behaviour.
  • Suppliers and Partners: Required to comply with our ethical standards and demonstrate responsible practices.

Reporting concerns

  • Employees can report concerns confidentially through our whistleblowing procedure.
  • Reports will be investigated promptly, fairly, and confidentially.
  • Whistleblowers will be protected from retaliation.

Training and awareness

  • All employees will be required to read our Ethics Policy and can raise any queries with a member of the People Team.

Monitoring and review

  • This policy will be reviewed annually to ensure compliance with UK legislation and best practice.
  • Internal audits will monitor adherence to ethical standards.
  • Feedback from employees, customers, and partners will be used to refine and strengthen our approach.

Continuous improvement

  • We recognize that ethics is an evolving area and commit to regularly updating our practices.
  • Emerging issues such as digital ethics, AI governance, and climate responsibility will be incorporated into our strategy.

Breach of policy

  • Breaches of this policy may result in disciplinary action, up to and including dismissal.
  • Breaches by suppliers or partners may result in termination of contracts or partnerships.
  • Serious breaches may be reported to regulators or law enforcement authorities.