Anti-Bribery and Corruption Policy

1. Purpose and scope

Steliam Resources Ltd is committed to conducting business fairly, honestly, and lawfully. This policy sets out our zero-tolerance approach to bribery and corruption in all jurisdictions where we operate. It applies to all employees, directors, officers, contractors, consultants, agents, and business partners acting on our behalf.

2. What we prohibit

We do not tolerate:

• Offering, promising, giving, or authorising any bribe, kickback, or improper payment.
• Requesting or accepting a bribe or improper advantage in connection with our business.
• Using third parties to channel bribes or corrupt payments.
• Facilitation payments made to secure or speed up routine government action.
• Gifts, hospitality, or entertainment that could influence a business decision or appear improper.

3. Gifts and hospitality

Gifts and hospitality must be modest, proportionate, properly recorded, and given in accordance with our internal procedures. They must never be offered or accepted with the intention of influencing a business decision or obtaining an improper advantage.

4. Third parties and business partners

We carry out risk-based due diligence on agents, contractors, suppliers, and other business partners before entering into commercial relationships. We expect our partners to uphold the same standards and include anti-bribery expectations in our contracts where appropriate.

5. Political and charitable contributions

Political contributions are not made on behalf of Steliam Resources without prior Board approval. Charitable donations and sponsorships must be transparent, legitimate, and made for genuine purposes — never as a means of securing a business advantage.

6. Training and record-keeping

Relevant employees and managers receive training on anti-bribery laws, red flags, and reporting channels. We keep accurate financial records and do not maintain undisclosed or off-book accounts.

7. Reporting concerns

Anyone who suspects a breach of this policy can report it through our whistleblower hotline or by contacting our ethics team. Reports will be handled confidentially and in accordance with our investigation procedures.

ethics@steliam.org

8. Consequences of breaches

Breaches of this policy may result in disciplinary action, termination of contracts, and referral to law enforcement or regulatory authorities. We will take appropriate action against any individual or business partner involved in bribery or corruption.

9. Approval and review

This policy was approved by the Board of Steliam Resources Ltd and will be reviewed periodically. Employees and business partners are expected to read, understand, and comply with this policy.