Anti-Bribery Policy

1. Policy statement

Red Cell Advisory is committed to conducting business with integrity and in compliance with all applicable anti-bribery and anti-corruption laws. We have zero tolerance for bribery and corruption in any form, whether direct or indirect.

2. Scope

This policy applies to all employees, contractors, consultants, agents, and business partners acting on behalf of Red Cell Advisory. It covers all business activities and relationships worldwide.

3. Definitions

Bribery: Offering, promising, giving, or accepting any financial or other advantage to induce or reward improper performance of a function or activity.

Corruption: The abuse of entrusted power for private gain.

Facilitation payments: Small payments made to secure or expedite routine government actions.

4. Prohibited conduct

The following activities are strictly prohibited:

• Offering, promising, or giving bribes to any person or organization
• Accepting or soliciting bribes from any person or organization
• Making facilitation payments to government officials
• Engaging in any form of corruption or fraudulent activity
• Failing to report known or suspected bribery or corruption

5. Gifts and hospitality

Modest gifts and reasonable hospitality may be acceptable if they are transparent, proportionate, and do not create an obligation or expectation of preferential treatment. All gifts and hospitality must be properly recorded and approved in accordance with our internal procedures.

6. Third-party relationships

We conduct appropriate due diligence on all business partners, agents, and intermediaries. Third parties acting on our behalf must comply with this policy and applicable anti-bribery laws. We do not tolerate bribery by third parties.

7. Reporting concerns

All employees and business partners must report suspected bribery or corruption immediately. Reports can be made to:

• Direct supervisor or management
• Legal department: legal@redcelladvisory.com
• Confidential ethics hotline (where available)

We prohibit retaliation against individuals who report concerns in good faith.

8. Training and awareness

All personnel receive regular training on anti-bribery policies and procedures. Training is tailored to roles and risk exposure, with enhanced training for high-risk positions.

9. Enforcement

Violations of this policy may result in disciplinary action up to and including termination of employment or business relationships. Violations may also result in criminal prosecution and civil liability.

10. Contact

For questions about this Anti-Bribery Policy, contact us at legal@redcelladvisory.com or:
Red Cell Advisory — a unit of Burakorn Partners Holding
30th Floor, Bhiraj Tower at EmQuartier, Sukhumvit Road, Khlong Tan Nuea, Watthana, Bangkok 10110