Nucleus is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK. Every employee and individual acting on Nucleus' behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

Nucleus considers that bribery and corruption has a detrimental impact on business by undermining good governance and distorting free markets.

Nucleus benefits from carrying out business in a transparent and ethical way and by helping to ensure that there is honest, open and fair competition in the financial services industry. Where there is a level playing field, Nucleus can lead the market through innovation and technical expertise and by delivering excellent service to our clients.

Transparent, fair conduct helps to foster deeper relationships of trust between Nucleus and its business partners and clients. It is vital for Nucleus' reputation and future growth.

Nucleus does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any persons or companies acting for it or on its behalf. The Board and Senior Management are committed to implementing and enforcing effective systems throughout Nucleus to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

Nucleus has issued an anti-bribery policy outlining the company's position on preventing and prohibiting bribery on the staff intranet and Nucleus website. The anti-bribery policy applies to all employees, including those of any subsidiary, as well as agency workers, consultants and contractors. All employees and other individuals acting for Nucleus are required to familiarise themselves and comply with the Nucleus anti-bribery policy with immediate effect.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of Nucleus are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures Nucleus is committed to transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure. Such expenditure must be authorised in advance, in accordance with the procedures set out in the Nucleus anti-bribery policy.

A breach of the Nucleus anti-bribery policy by an employee will be treated as grounds for disciplinary action. Employees and other individuals acting for the company should note that bribery is a criminal offence that may result in up to 10 years' imprisonment and/or an unlimited fine for the individual and an unlimited fine for Nucleus.

Nucleus will not conduct business with service providers, agents or representatives that do not support the Nucleus anti-bribery objectives. Nucleus reserves the right to terminate its contractual arrangements with any third parties acting for, or on behalf of, Nucleus with immediate effect where there is evidence that they have committed acts of bribery.

The success of Nucleus' anti-bribery measures depends on all employees, and those acting for Nucleus, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, Nucleus are encouraged to report any suspected bribery in accordance with the procedures set out in the anti-bribery policy. Nucleus will support any individuals who make such a report, provided that it is made in good faith.

Anti-Bribery Act Company Statement, 2025