ESG Policy

1. Purpose and Objectives

Apolonia Capital recognises that strong Environmental, Social and Governance (ESG) practices are essential to sustainable value creation, sound risk management, and responsible business conduct. This ESG Policy sets out the principles, commitments, and governance framework through which Apolonia Capital integrates ESG considerations into its operations, advisory activities, and internal decision‑making processes. The objectives of this Policy are to:

• Embed ESG considerations into Apolonia Capital’s corporate culture and governance framework;
• Promote responsible, ethical, and sustainable business practices;
• Support compliance with applicable UAE laws, SCA regulations, and international best practices;
• Identify, assess, and manage ESG‑related risks and opportunities relevant to the Company’s activities; and
• Enhance transparency and accountability to regulators, clients, partners, and other stakeholders.

2. Scope and Applicability

This Policy applies to:

• Apolonia Capital For Financial Consultation & Financial Analysis LLC;
• The Board of Directors, senior management, employees, and authorised representatives of the Company; and
• Where relevant, third‑party service providers, consultants, and counterparties engaged by Apolonia Capital.

This Policy is proportionate to the Company’s licensed activities under the UAE Securities and Commodities Authority (SCA) Category 5 licence and is aligned with Apolonia Capital’s role as an advisory and consulting firm.

3. Regulatory and Best‑Practice Framework

This Policy is informed by, and aligned with, the following frameworks (as applicable):

• UAE laws and regulations, including SCA Rulebooks and guidance;
• Federal AML/CFT and corporate governance requirements;
• FATF principles on governance and risk management (where relevant);
• UN Principles for Responsible Business Conduct;
• OECD Guidelines for Multinational Enterprises; and
• Relevant international ESG and sustainability best practices, applied on a risk‑based and proportionate basis.

4. ESG Governance Structure

4.1 Board of Directors The Board of Directors has ultimate oversight responsibility for ESG matters and is responsible for:

• Approving the ESG Policy and any material updates;
• Overseeing ESG‑related risks and governance arrangements; and
• Ensuring ESG considerations are appropriately embedded within the Company’s strategy and control framework.

4.2 Senior Management Senior Management is responsible for:

• Implementing this ESG Policy;
• Ensuring ESG considerations are integrated into day‑to‑day operations;
• Supporting a culture of ethical conduct and sustainability; and
• Reporting ESG‑related matters to the Board, as appropriate.

4.3 Compliance Function The Compliance Officer / MLRO shall:

• Monitor adherence to this Policy;
• Ensure alignment with regulatory and internal governance requirements;
• Incorporate relevant ESG considerations into compliance, risk assessments, and due‑diligence processes; and
• Support ESG‑related reporting and record‑keeping.

5. Environmental Principles

Apolonia Capital is committed to minimising its environmental footprint in a manner proportionate to its business activities. Key commitments include:

• Promoting efficient use of resources (energy, water, paper);
• Encouraging digital‑first processes to reduce paper consumption;
• Complying with applicable environmental laws and regulations in the UAE;
• Encouraging environmentally responsible practices among employees and service providers, where feasible; and
• Considering environmental risk factors, where relevant, in advisory and engagement decisions.

Given the Company’s advisory nature, Apolonia Capital does not directly engage in environmentally intensive activities but remains committed to responsible environmental conduct. 6.1 Employees and Workplace The Company commits to:

• Providing a professional, safe, and respectful working environment;
• Promoting equal opportunity and non‑discrimination;
• Supporting employee development, training, and professional competence;
• Upholding labour laws and employment standards applicable in the UAE; and
• Maintaining clear policies on conduct, ethics, conflicts of interest, and whistleblowing.

6.2 Clients and Counterparties Apolonia Capital commits to:

• Acting honestly, fairly, and professionally in the best interests of clients;
• Applying appropriate client due diligence and risk‑based onboarding standards;
• Avoiding involvement in activities linked to corruption, financial crime, or unethical conduct; and
• Maintaining confidentiality and data protection standards.

6.3 Community and Society Where appropriate, the Company may:

• Support responsible business initiatives;
• Encourage ethical and sustainable business practices within its network; and
• Contribute to awareness of good governance and compliance standards.

7. Governance Principles

Strong governance underpins Apolonia Capital’s ESG framework. Key governance commitments include:

• Maintaining a clear organisational and governance structure;
• Adhering to high standards of integrity, ethics, and professionalism;
• Ensuring independence and objectivity in advisory activities;
• Managing conflicts of interest transparently and effectively;
• Maintaining robust AML/CFT, sanctions, and risk‑management frameworks;
• Ensuring accurate record‑keeping, reporting, and regulatory engagement.

9. Monitoring, Reporting and Review

• Compliance with this Policy will be monitored by the Compliance Function;
• ESG‑related matters may be reported to senior management and the Board, as appropriate;
• This Policy shall be reviewed at least annually, or earlier if required due to regulatory, business, or risk changes; and
• Any material breaches of this Policy shall be escalated in line with internal governance procedures.

10. Training and Awareness

Apolonia Capital shall ensure that:

• Relevant employees are made aware of this ESG Policy;
• ESG considerations are embedded within compliance and governance training programmes; and

Ongoing awareness is maintained through internal communications and updates.

11. Policy Approval and Ownership

This ESG Policy is approved by the Board of Directors of Apolonia Capital For Financial Consultation & Financial Analysis LLC. Policy Owner: Compliance Officer / MLRO : Jinoy Manoharan Effective Date: 18/12/2025 Review Cycle: Annually.