PARAGON MICROFIBRE LTD

ANTI-BRIBERY AND CORRUPTION POLICY

Policy Version: 1.0
Effective Date: 3 November 2026
Policy Owner: Company Directors
Review Frequency: Annually
Approved By: Stephen Dufell

1. POLICY STATEMENT

Paragon Microfibre Ltd is committed to conducting all business activities with honesty, integrity, transparency and professionalism.

The Company adopts a zero-tolerance approach to bribery, corruption and unethical business practices in all aspects of its operations.

We are committed to complying with all applicable anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010.

This policy establishes the standards of conduct expected from all employees, directors, contractors, suppliers, agents and other individuals or organisations acting on behalf of Paragon Microfibre Ltd.

No employee or representative shall engage in bribery or corruption, regardless of whether such conduct is intended to benefit the Company.

2. PURPOSE

The purpose of this policy is to:

• Prevent bribery, corruption and unethical business practices.

• Ensure compliance with applicable anti-bribery legislation.

• Establish clear expectations for employees and business partners.

• Provide guidance on identifying and reporting suspected bribery.

• Protect the reputation, integrity and commercial interests of Paragon Microfibre Ltd.

• Promote transparency and accountability throughout the Company's operations.

3. SCOPE

This policy applies to:

• All Company directors and senior management.

• All permanent, temporary, part-time and agency employees.

• Contractors, consultants and representatives acting on behalf of the Company.

• Agents, intermediaries and other associated persons.

• Suppliers, distributors and other business partners, where applicable to their dealings with the Company.

The policy applies to all business activities undertaken within the United Kingdom and internationally.

All individuals acting on behalf of Paragon Microfibre Ltd are expected to comply with this policy and applicable legislation.

4. LEGAL FRAMEWORK

The UK Bribery Act 2010 establishes offences relating to:

1. Offering, promising or giving a bribe.

2. Requesting, agreeing to receive or accepting a bribe.

3. Bribing a foreign public official.

4. Failure by a relevant commercial organisation to prevent bribery by associated persons, where the statutory requirements are met.

Breaches of the legislation may result in serious criminal penalties, including imprisonment for individuals and unlimited fines for organisations.

Paragon Microfibre Ltd will take reasonable and proportionate steps to prevent bribery within its business operations.

5. DEFINITION OF BRIBERY

Bribery involves offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage in circumstances that constitute an offence under applicable anti-bribery legislation.

Bribery may include, but is not limited to:

• Offering money to secure a business contract.

• Accepting personal payments in exchange for preferential supplier treatment.

• Providing gifts or benefits intended to influence purchasing decisions improperly.

• Offering incentives to obtain confidential commercial information improperly.

• Making unofficial payments to accelerate routine government or administrative processes.

• Providing inappropriate rewards in exchange for business opportunities.

A bribe does not have to involve cash. Gifts, hospitality, discounts, services, employment opportunities and other personal benefits may constitute bribes depending on the circumstances.

6. GIFTS AND HOSPITALITY

Paragon Microfibre Ltd recognises that reasonable and proportionate business gifts and hospitality may form part of legitimate commercial relationships.

However, gifts and hospitality must never be offered or accepted with the intention of improperly influencing a business decision or securing an unfair advantage.

All gifts and hospitality must:

• Be reasonable, appropriate and proportionate.

• Be offered or accepted openly and transparently.

• Have a legitimate business purpose.

• Not create an obligation or expectation of preferential treatment.

• Comply with applicable laws and regulations.

• Be accurately recorded where required by Company procedures.

Employees must seek approval from a Company Director before offering or accepting any gift or hospitality that could reasonably be perceived as influencing a commercial decision.

Cash gifts or cash-equivalent benefits must not be offered or accepted where doing so would constitute bribery or create an improper inducement.

7. SUPPLIERS AND BUSINESS PARTNERS

Paragon Microfibre Ltd expects its suppliers, manufacturers, distributors, contractors and other business partners to operate ethically and comply with applicable anti-bribery legislation.

The Company will not knowingly engage with organisations or individuals involved in bribery or corrupt practices.

Where appropriate, the Company will:

• Undertake proportionate checks on new suppliers and business partners.

• Communicate its anti-bribery expectations.

• Review concerns regarding unethical business conduct.

• Take appropriate action where evidence of bribery or corruption arises.

• Terminate commercial relationships where justified by serious breaches.

All supplier selection and purchasing decisions must be based on legitimate commercial considerations, including quality, price, reliability, service and contractual requirements.

8. FACILITATION PAYMENTS AND KICKBACKS

Paragon Microfibre Ltd prohibits facilitation payments and kickbacks.

Facilitation payments are unofficial payments intended to secure or accelerate routine actions, such as customs clearance, licensing or administrative approvals.

Kickbacks are improper payments or benefits provided in exchange for favourable business treatment.

Employees and representatives must not offer, request, make or accept such payments.

Where a payment is demanded under circumstances involving an immediate threat to personal safety, individuals should prioritise their safety and report the incident to a Company Director as soon as reasonably practicable.

9. CHARITABLE DONATIONS AND POLITICAL CONTRIBUTIONS

Any charitable donation made on behalf of Paragon Microfibre Ltd must be legitimate, transparent and appropriately authorised.

Charitable donations must not be used to disguise bribery or improperly influence commercial decisions.

The Company will not make political contributions intended to obtain an improper business advantage.

Any proposed political contribution made on behalf of the Company must receive prior approval from the Company Directors and comply with applicable legislation.

10. CONFLICTS OF INTEREST

Employees and representatives must avoid situations where personal interests could improperly influence their professional responsibilities.

Potential conflicts of interest may include:

• Personal financial interests in suppliers or customers.

• Family relationships affecting purchasing decisions.

• Receiving personal benefits from commercial partners.

• Outside business activities that conflict with Company interests.

Any actual or potential conflict of interest must be disclosed promptly to a Company Director.

The Company will assess disclosed conflicts and determine appropriate measures to manage them.

11. RECORD KEEPING AND FINANCIAL CONTROLS

Paragon Microfibre Ltd is committed to maintaining accurate and transparent financial records.

All payments, expenses, gifts, hospitality and commercial transactions must be recorded accurately and supported by appropriate documentation.

The following practices are prohibited:

• Creating false or misleading invoices.

• Recording fictitious business expenses.

• Concealing unauthorised payments.

• Maintaining undisclosed funds for improper purposes.

• Falsifying accounting records to disguise bribery or corruption.

The Company will maintain financial controls appropriate to the size, nature and risk profile of its operations.

12. EMPLOYEE RESPONSIBILITIES

All employees and individuals acting on behalf of Paragon Microfibre Ltd are responsible for:

• Reading, understanding and complying with this policy.

• Acting honestly and ethically in business dealings.

• Avoiding conduct that could constitute bribery or corruption.

• Reporting suspected breaches promptly.

• Cooperating with any internal investigation.

• Seeking guidance where uncertainty exists.

Company Directors are responsible for promoting compliance, reviewing identified risks and ensuring that appropriate preventive measures are maintained.

13. REPORTING SUSPECTED BRIBERY OR CORRUPTION

Employees, suppliers and other relevant parties are encouraged to report any suspected bribery, corruption or unethical conduct.

Concerns should be reported to a Company Director or another appropriate senior representative.

Reports may relate to:

• Requests for suspicious payments.

• Offers of improper financial incentives.

• Undisclosed conflicts of interest.

• Suspected fraudulent transactions.

• Unusual supplier arrangements.

• Any other conduct that may breach this policy.

All reports will be treated seriously and handled as confidentially as reasonably practicable.

Individuals raising genuine concerns will not be subjected to retaliation or detrimental treatment for doing so, even where the concern is ultimately not substantiated.

Nothing in this policy prevents an individual from making a protected disclosure under applicable whistleblowing legislation or reporting suspected criminal activity to the appropriate authorities.

14. INVESTIGATION AND DISCIPLINARY ACTION

Paragon Microfibre Ltd will investigate credible allegations of bribery or corruption fairly and proportionately.

Where a breach is established, appropriate action may include:

• Additional training or corrective measures.

• Formal disciplinary action.

• Dismissal, including dismissal for gross misconduct where justified.

• Termination of supplier or contractor relationships.

• Referral to law enforcement or relevant regulatory authorities.

Any disciplinary action will be undertaken in accordance with applicable employment legislation and Company procedures.

15. TRAINING AND COMMUNICATION

The Company will ensure that employees and relevant representatives are made aware of this policy.

Anti-bribery guidance or training will be provided where appropriate, taking account of an individual's role and the risks associated with their responsibilities.

This policy will be made available to relevant employees and, where appropriate, suppliers and business partners.

16. RISK ASSESSMENT AND MONITORING

Paragon Microfibre Ltd will assess bribery and corruption risks proportionately, taking account of its business activities, commercial relationships and operating locations.

Particular attention may be given to:

• Supplier and manufacturer relationships.

• Purchasing and procurement activities.

• International trading arrangements.

• Third-party agents and intermediaries.

• Gifts, hospitality and commercial incentives.

• Transactions involving public officials.

The Company will review its anti-bribery controls periodically and implement improvements where necessary.

17. POLICY REVIEW

This policy will be reviewed at least annually or sooner where required by:

• Changes in applicable legislation.

• Changes in the Company's business operations.

• Identification of new bribery or corruption risks.

• Findings arising from investigations or compliance reviews.

Responsibility for maintaining and updating this policy rests with the Company Directors.

18. COMMITMENT TO COMPLIANCE

Paragon Microfibre Ltd is committed to maintaining high standards of ethical business conduct.

Bribery and corruption are unacceptable and will not be tolerated in any part of the Company's operations.

All employees, representatives and relevant business partners are expected to uphold the principles of this policy and contribute to a transparent, responsible and lawful business environment.