Anti-Bribery and Corruption Policy

FULCRUM TECHNOLOGIES PTE. LTD.

Introduction

fulcrum strives to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and implementing and enforcing effective systems to counter bribery. fulcrum expects the same approach from all those with whom we do business.

The following sets out fulcrum's position on bribery and corruption.

What is Bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Bribery includes:

• Payments to a company's employees or their relatives, or to those of a third party, to secure a business advantage
• Gifts, hospitality and expenses payments made to secure a business advantage
• Political contributions made to secure a business advantage
• Facilitation payments or "kickbacks" made to secure or accelerate routine or necessary business actions

Scope

This policy applies to all fulcrum's employees and associated persons acting on behalf of fulcrum, and extends to our business dealings in all jurisdictions within which we operate.

Policy

fulcrum does not engage in bribery or corruption. It is contrary to fulcrum's policy for any employee or third party acting on behalf of fulcrum to request, offer, solicit, make or receive any payments or inducements which are illegal, unethical or represent a breach of trust.

fulcrum respects all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific or local business practices.

fulcrum will not do business with any person or company which we know (or have reasonable grounds for suspecting) engages in bribery or corruption.

Compliance

Compliance with this policy will be subject to regular review and audit, to ensure it remains suitable, effective and proportionate having regard to fulcrum's operations and the jurisdictions within which we operate.

Any concerns raised by any person relating to any alleged non-compliance with the terms of this policy will be immediately investigated and, if appropriate, action will be taken.

Failure to observe the terms of this policy may constitute a disciplinary offence and may expose individuals to civil or criminal proceedings.

Last revised: March 2026