Anti-Bribery Policy

Tower Peak Partners takes a zero-tolerance approach to bribery and corruption. As a private markets firm operating across multiple jurisdictions, the firm recognises the heightened exposure that comes with complex financial transactions, dealings with government entities, and the ownership of portfolio companies in different legal environments.

The firm complies with all applicable anti-bribery law, including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act.

The policy binds all employees, officers, directors and partners, and equally binds contractors, agents, consultants, intermediaries and any other party acting on the firm's behalf.

It also applies to portfolio company executives, who are required to adopt and implement anti-bribery and anti-corruption procedures as part of post-acquisition integration.

It governs interactions with portfolio companies, with financial institutions, regulators, investors, suppliers and business partners, with domestic and foreign government officials and public bodies, and with third-party service providers.

Offering, promising, giving, soliciting or receiving any bribe or improper advantage in order to influence a business decision.

Facilitation payments of any kind — small unofficial payments to public officials to expedite routine administrative tasks. These are prohibited regardless of local custom or practice, and regardless of how minor the amount.

Kickbacks from any third party, including agents, suppliers and intermediaries, in return for favourable treatment.

Gifts, hospitality or entertainment that are lavish, inappropriate, or capable of being seen as influencing a business decision. Anything given or accepted must be reasonable and proportionate, consistent with customary business practice, compliant with local law, and recorded. Gifts and hospitality above an approval threshold require the Chief Compliance Officer's sign-off and are entered in the firm's gifts and hospitality register.

Dealings with public officials carry particular care: no advantage of any kind may be offered to a public official to influence their actions, and any request for an improper payment or benefit must be reported to the Chief Compliance Officer immediately.

Before any acquisition or investment, anti-corruption due diligence assesses the target's exposure to bribery and corruption risk — with particular attention to jurisdictions where such practices are known to be prevalent — its existing policies and controls, any history of regulatory violations or allegations, and its relationships with government officials and regulatory bodies.

This diligence is integrated into the firm's wider environmental, social and governance assessment rather than run alongside it.

After acquisition, portfolio companies are required to adopt a framework meeting the firm's standards, to train their management and staff, and to operate a confidential whistleblowing channel of their own. Failure to implement or comply may result in termination of the relationship, legal action and other remedial steps.

Anyone — employee, portfolio company representative or third party — who suspects bribery, corruption or related unethical conduct is required to report it immediately, either to the Chief Compliance Officer or through the firm's confidential whistleblowing channel.

Reports may be made confidentially through the firm's independent whistleblowing service, which is listed under Key Disclosures.

The firm's Global Management Committee holds ultimate responsibility for compliance with this policy, approves the annual anti-bribery and anti-corruption statement, and conducts periodic audits of the firm's operations and its portfolio companies.

The Chief Compliance Officer is responsible for embedding the policy across the firm and its portfolio companies, for leading risk assessment and monitoring, and for coordinating training. Training is mandatory and recurring for employees, portfolio company management and relevant third parties.

A breach may result in termination of employment or contract, legal action including referral to law enforcement, personal and corporate fines and sanctions, and termination of the business relationship.

The policy is reviewed annually by the Chief Compliance Officer and approved by the Management Committee, and earlier where a change in law, in best practice, or the discovery of a significant risk requires it.