Ethical Business Conduct Policy

MICAM Ltd. recognises the importance of adhering to the principles of ethical business conduct in the delivery of its activities and is committed to operating its business sustainably and responsibly and in full compliance with all relevant laws and regulations.

This policy applies to MICAM Ltd., its officers, directors, and employees, whether permanent or temporary. It also applies to all MICAM supply chain partners, including agents, consultants, joint venture partners and subcontractors (“Associated Persons”).

ss conduct includes:

• Bribery prevention – The giving or receiving of bribes is contrary to the bribery legislation and can play no part in the way in which MICAM carries out its business.
• Fair and open competition – MICAM adheres in all its business practices to the principle of fair and efficient competition, and does not engage in conduct which, is anti-competitive – such as entering into agreements which restrict, prevent or distort competition.
• Insider dealing prevention – If you are in possession of inside information about the MICAM, you must not deal in any securities (shares) of the company, or encourage or recommend someone else to do so, even if you will not directly profit from the dealing.
• Fraud prevention – MICAM has a zero-tolerance approach to fraud within the group or by any Associated Persons and will investigate all reports of suspicious or dishonest behaviour in accordance with the fraud response policy.
• Whistleblowing – MICAM encourages employees and Associated Persons to raise their concerns about any malpractice at the earliest possible stage. This is commonly known as “whistleblowing”.

This policy is a declaration of MICAM’s intent to ensure all employees and Associated Persons act, and are seen to act, with uncompromising honesty and integrity in everything they do.

Patrick Dunlea, Finance Director
MICAM Ltd.

5th of October 2023