POLICIES

ANTI-BRIBERY AND ANTI-CORRUPTION (ABAC) POLICY STATEMENT

Eruditus Learning Solutions Pte Ltd and its subsidiaries (collectively, Eruditus Group)are committed to operating in an ethical manner and in compliance with applicable anti-bribery laws and regulations in all jurisdictions in which we operate. The Eruditus Group takes a zero-tolerance approach towards bribery and corruption in any form. We prohibit the direct or indirect giving or receiving of improper payments or other benefits for purposes of obtaining any advantage. We expect all of our directors, officers, employees, business partners and third parties (collectively, Stakeholders) to act professionally and fairly by maintaining the highest standards of ethics and integrity in all their business dealings. To achieve this, the Eruditus Group has implemented and enforced our ABAC policies as briefly described in this Policy Statement, and will continue to implement and enforce, such policies and other effective systems to counter improper activities.

We prohibit facilitation payments. Stakeholders must not pay any amount as facilitation payment on our behalf irrespective of whether reimbursement for such payment is claimed. All Stakeholders are required to adhere to our ABAC policies or face consequences imposed by the Eruditus Group and/or civil and criminal prosecutors.

All Stakeholders play an important role in conducting business in an ethical manner and in conjunction with applicable local and other regulations and laws in the geographies where we operate.

We reserve the right to periodically update our policies and other governance instruments. Stakeholders who fail to comply with these policies, or applicable laws or regulations will be subjected to disciplinary action including but not limited to termination of employment or contract(s), or legal proceedings.

Discrimination, victimization, retaliation, harassment of any kind or any unfair practices (such as threat or intimidation, demotion, transfer, refusal of promotion, impact on performance measures, talent assessments or evaluation, etc.) against anyone who reports any potential wrongdoings of our policies in good faith or anyone who cooperates or provides information/data relating to the Eruditus Group or governmental authorities in connection with an investigation, will not be tolerated.

Please refer to our ABAC policy here.

VENDOR CODE OF CONDUCT

Eruditus Learning Solutions Pte Ltd and its subsidiaries (collectively, Eruditus Group) Vendor Code of Conduct (referred as “Code”) establishes business practices that are expected from Vendors in the course of their dealings with Eruditus Group.

Eruditus Group is strongly committed to observing the highest ethical standards in conducting its business with Vendors. The Code outlines the minimum compliance requirements from Vendors in all procurement dealings to ensure sustainability, transparency and accountability.

Eruditus Group may amend and add to this Code at any time and Vendors and Vendor Representatives are bound by such amendments and additions published from time to time. It is the responsibility of the Vendor to ensure that Vendor Representatives comply with this Code.

Please refer to our Vendor Code of Conduct here.