Date of this code: January 2025

About this code

Corporate integrity, responsible sourcing, environmental sustainability and the safety and wellbeing of workers where we do business are of paramount importance to Puma Investment Management Limited and all its subsidiaries (together the “Puma Capital Group”). These core principles are reflected in this Supplier Code of Conduct (“Code”), which establishes the minimum standards and behaviours that must be met by any entity that supplies products or services to the Puma Capital Group and to any funds or entities managed or advised (as applicable) by the Puma Capital Group. The terms of this Code are in addition to any other agreed commercial or contractual terms.

Definitions and scope

In this Code:

Supplier means a body corporate, partnership or individual that provides goods or services to the Puma Capital Group and references to Supplier shall include that supplier’s subcontractors, suppliers and agents.

Worker means any individual whom the Supplier employs, hires or engages, or otherwise uses to conduct its business.

Who must comply with this code?

The Supplier shall comply with the Code and shall ensure that its Workers are aware of this Code and comply with it.

Supplier's commitment

By supplying goods or services to Puma Capital Group, the Supplier agrees that:

• It will comply with the requirements in this Code.
• It has appropriate systems in place to ensure continuous compliance and to demonstrate such compliance.

1. Compliance with laws and regulations and competing standards

1.1 The Supplier shall operate in compliance with all applicable laws and regulations from time to time in force, including laws and regulations relating to issues addressed in this Code.

1.2 Competing standards shall be addressed as follows:

1. If there is a conflict between any applicable laws or regulations, the provisions of an agreement with Puma Capital Group and the provisions of this Code, the Supplier shall meet the most stringent standard.
2. If there is a conflict between the provisions of an agreement with Puma Capital Group and the provisions of this Code, the Supplier shall meet the standard as set out in the agreement.

2. Updating this Code

Puma Capital Group may modify this Code from time to time and the latest version of the Code will be available on our website.

3. Workforce issues

3.1 Slavery, human trafficking and child labour. The Supplier shall comply with all applicable anti- slavery and human trafficking laws, statutes, regulations from time to time in force including the Modern Slavery Act 2015 in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.

3.2 Human rights. The Supplier shall comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work from time to time in force in any part of its supply chain.

3.3 Equal opportunities. Puma Capital Group is an equal opportunities employer and seeks to work with like-minded suppliers. Suppliers shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than a Worker's ability to perform the job subject to any accommodations required or permitted by law.

3.4 Freedom of association and collective bargaining. The Supplier shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.

3.5 Working environment. The Supplier shall provide a safe, healthy, and sanitary working environment and comply with UK health and safety laws and any other relevant laws where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. Where applicable, where such hazards cannot be adequately prevented or controlled, the Supplier shall provide workers with appropriate personal protective equipment to protect against hazards typically encountered in that scope of work.

3.6 Wages and remuneration. The Supplier must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:

1. the minimum wage (or as applicable, minimum living wage) and benefits established by applicable law;
2. collective agreements;
3. industry standards; and
4. an amount sufficient to cover basic living requirements.

4. Data protection and information security

4.1 The Supplier shall comply with all data protection laws and requirements (including the UK GDPR) when processing any personal data on Puma Capital Group’s behalf.

4.2 The Supplier shall have in place appropriate measures to:

1. protect the integrity and confidentiality of information (including information belonging to or supplied by Puma Capital Group) held on its systems (which include physical and online or electronic systems); and
2. ensure that there is no unauthorised access of the information by third parties, including its suppliers, sub-contractors and agents.

5.  Environmental responsibility

5.1 The Supplier shall ensure that:

1. its operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) climate change, waste disposal, emissions, discharges and the handling of hazardous and toxic materials;
2. where applicable, the goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties; and
3. it will only use packaging materials that comply with all applicable environmental laws and treaties.

6. Bribery and corruption

6.1 The Supplier shall comply with all applicable laws, statutes and regulations relating to the prevention of bribery, corruption and fraud (including but not limited to the Bribery Act 2010, Criminal Finances Act 2017 and Economic Crime and Corporate Transparency Act 2023). To that end, the Supplier shall not:

1. accept, offer, promise, pay, permit or authorise:
   1. bribes, facilitation payments, kickbacks or illegal political contributions;
   2. money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or
   3. any other unlawful or improper payments or benefits.
2. engage in any activity, practice or conduct that would constitute fraud or a fraud offence under the Economic Crime and Corporate Transparency Act 2023;
3. evade or facilitate the evasion of tax by another person anywhere in the world.

7. Unfair business practices

The Supplier shall comply with all applicable competition laws (including but not limited to the Competition Act 1998), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.

8. Certifying compliance and audit

8.1 The Supplier shall, on written request from the Puma Capital Group, provide written confirmation that:

1. it has appropriate systems in place to monitor its compliance with this Code; and
2. it is able to comply with this Code for the duration of its relationship with Puma Capital Group.

8.2 In addition to the written confirmation above, Puma Capital Group may conduct audits and inspections to verify the Supplier's compliance with this Code, on giving the Supplier reasonable notice. Puma Capital Group has no obligation to conduct such audits or inspections.

9. Self-monitoring, reporting breaches, remediation and consequences of breach

9.1 The Supplier shall monitor its compliance with the Code and shall report any breaches (actual or suspected) of this Code as soon as possible to your main contact at Puma Capital Group.

9.2 Where a breach has been reported, the Supplier and Puma Capital Group will agree a schedule of remediation where appropriate. It may not be appropriate or possible to agree a schedule of remediation where the violation is severe or incurable, or where it constitutes a violation of law.

9.3 In the case of material breaches, repeated breaches, or failure to remediate where a remediation schedule has been agreed, Puma Capital Group may suspend or terminate its relationship with the Supplier. In the case of a violation of law, Puma Capital Group will also disclose the matter to the appropriate authorities.

9.4 The Supplier shall not retaliate or take disciplinary action against any Worker that has, in good faith, reported breaches of this Code or questionable behaviour, or who has sought advice regarding this Code.