Anti-Bribery and Anti-Corruption Notice

Our Commitment

Faropoint Ventures, LLC is committed to conducting business with the highest standards of integrity and ethical behavior. We maintain a zero-tolerance policy toward bribery and corruption in all forms and in all jurisdictions where we operate.

Prohibition on Corrupt Practices

We strictly prohibit all employees, officers, and associated persons from, directly or indirectly:

• Making or authorizing improper payments to any government official, political candidate, or private party to obtain or retain business advantages
• Offering anything of value to foreign officials, employees of state-owned enterprises, or public international organizations for the purpose of influencing official decisions
• Engaging in “pay to play” arrangements whereby political contributions are made to government officials to secure or compete for investment management contracts
• Circumventing these policies through indirect means, including payments through third parties, family members, or affiliated entities

Compliance with Law

Our policy ensures full compliance with:

• The U.S. Foreign Corrupt Practices Act (FCPA)
• “Pay to Play” regulations
• All applicable anti-bribery and anti-corruption laws in jurisdictions where we conduct business

Pre-Clearance Requirements

All employees must obtain prior written approval from our Compliance department before:

• Making any payment or providing anything of value to a foreign official
• Making any political contribution to candidates, political parties, or political action committees

Reporting Concerns

If you become aware of any potential violations of this policy, please contact our Compliance group by emailing compliance@faropoint.com. We prohibit retaliation against anyone who reports concerns in good faith.