Policy Statement

Brightness Capital & Asset Advisory Pte Ltd (“Brightness Capital” or “the Company”) is committed to conducting its business with integrity and transparency. We take a zero-tolerance approach to modern slavery, forced labour, human trafficking, and all forms of exploitation in our operations, supply chains, and business relationships.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, debt bondage, and human trafficking—all of which are strictly prohibited under international law and Singapore’s Prevention of Human Trafficking Act 2014.

This policy outlines our commitment to preventing modern slavery and the steps we take to identify and mitigate such risks within our business and supply chains.

2. Scope

This policy applies to all employees, directors, contractors, consultants, suppliers, service providers, and any third parties working with or on behalf of Brightness Capital.

3. Our Commitment

Brightness Capital will:

• Ensure that our operations and supply chains are free from any form of modern slavery;

• Conduct due diligence on new suppliers, partners, and third-party service providers;

• Monitor existing relationships to assess the risk of slavery and human trafficking;

• Act promptly if we discover any practices or incidents inconsistent with this policy;

• Provide training to relevant employees to help them understand and identify modern slavery risks;

• Encourage a culture of ethical conduct, transparency, and whistleblowing;

4. Risk Management and Due Diligence

Brightness Capital recognises that financial services may have indirect exposure to modern slavery, particularly through investments, procurement, outsourcing, and third-party services.

To manage this risk, Brightness Capital:

• Evaluates suppliers and vendors on their ethical practices and compliance history;

• Includes modern slavery clauses in supplier and service contracts;

• Requires that partners and contractors uphold equivalent standards;

• Reviews procurement processes to ensure ethical sourcing;

5. Reporting and Whistleblowing

Brightness Capital encourages the reporting of any concerns relating to modern slavery. All employees, stakeholders, and external parties can report suspected violations confidentially via our whistleblowing mechanism.

All reports will be taken seriously and investigated appropriately. No retaliation will be permitted against anyone who raises a concern in good faith.

6. Roles and Responsibilities

• Board of Directors: Oversees policy enforcement and ensures compliance across the company;

• Compliance Team: Implements and monitors policy application, conducts due diligence, and manages training.

• All Employees: Must remain vigilant and report any suspected breaches of this policy.

7. Training and Awareness

Brightness Capital will provide periodic training to relevant employees, particularly those in roles involving procurement, compliance, or third-party relationships. This will ensure that modern slavery risks are understood and actively addressed.

8. Review and Updates

This policy will be reviewed annually and updated as necessary to reflect changes in legislation, company operations, or risk exposure. Brightness Capital remains committed to continuous improvement in combatting modern slavery.

9. Approval and Publication

This policy is approved by the Brightness Capital Board of Directors and is publicly available on the company’s website. Suppliers, partners, and other stakeholders are encouraged to familiarise themselves with this policy and ensure alignment with its principles.