Anti-Bribery Policy and Policy for The Prevention of Tax Evasion

ANTI-BRIBERY POLICY AND POLICY FOR THE PREVENTION OF TAX EVASION

In accordance with the UK Bribery Act 2010, HydrogenOne Capital Growth plc (the “Company“) has developed appropriate anti-bribery policies and procedures. The Company has a zero-tolerance policy towards bribery and is committed to carrying out its business fairly, honestly and openly. The anti-bribery policies and procedures apply to all its officers and to those who represent the Company (including its business partners). The Company expects those providing services to it, or on its behalf, to undertake their business without bribery.

The Criminal Finances Act (Commencement No. 1) Regulations 2017 (SI 2017/739) brought Part 3 of the Criminal Finances Act 2017, the corporate offences of failure to prevent facilitation of tax evasion, into force on 30 September 2017. The Company does not tolerate tax evasion in any of its forms in its business. The Company complies with the relevant UK law and regulation in relation to the prevention of facilitation of tax evasion and supports efforts to eliminate the facilitation of tax evasion worldwide, and works to make sure its business partners share this commitment.

The Company assesses the nature and extent of its exposure to the risk of those who act for or on its behalf engaging in bribery or activity during the course of business to criminally facilitate tax evasion. The Company applies due diligence procedures, taking an appropriate and risk based approach in relation to those who perform, or will perform services on its behalf, in order to mitigate identified risks relating to bribery and the facilitation of tax evasion.

2021