Statement of Ethics.

QuantSpark is a data science consultancy. We create meaningful insight from complex data and use this to build analytical tools that solve strategic problems, helping our clients make significant and lasting improvements to their performance and realize their most important goals. We pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organisation.

QuantSpark condemns corruption in all its forms and we will not tolerate it in our business or in those we do business with. From the confines of our working environments, it is sometimes difficult to grasp the scale of the damage that bribery does to societies. It is not a victimless crime.

Our Anti-Bribery Policy sets out in detail how you should behave and what you should do if you are confronted with corruption. We expect that all of you will embrace the Policy and its values and use them in all aspects of your day-to-day work.

The Policy is for your benefit as much as for QuantSpark's. If convicted of a bribery offence, QuantSpark might get a significant fine and suffer lasting reputational damage. If you are convicted of a bribery offence, you could face up to ten years in prison. The potential harm done by bribery, both to QuantSpark and to you, is long term and hugely outweighs any potential short-term gain. Bribery is just not worth the risk.

If you have any doubts about anything at all, refer to the Anti-Bribery Policy or you can speak to your line manager, Adam Hadley or HR in complete confidence. We are committed to eradicating corruption and we will stand by you in acting ethically.

Remember, take the RIGHT approach, and we can eradicate corruption together:

• Responsibility. You are responsible for your actions. If you break the law, you will have to face the consequences - which could mean a fine, imprisonment, or both.

• Integrity. Don't compromise your integrity. If you think something is wrong, ALWAYS report it. If you aren't sure, consult the Anti-Bribery Policy. Don't ever let yourself be forced into doing something you know, or suspect is wrong.

• Genuineness. Always pay genuine prices for genuine goods and services. Never pay over the odds. Agents who ask for especially large fees or commissions may do so in order to pay bribes on your behalf. If this happens, you will be responsible. Excessive payments are obvious and will always be uncovered.

• Honesty. Act honestly and in good faith at all times and in all aspects of your work.

• Transparency. Keep accurate records (including all invoices and receipts) of everything that you do, especially in relation to the payments you make and what they are for. Full and accurate records demonstrate complete transparency and that you have nothing to hide.

Don't bribe. Do the RIGHT thing.

Adam Hadley, CEO & Founder, QuantSpark Limited