Linq Africa (Pty) Ltd — Code of Ethics and Business Conduct

Version 1.0 · Adopted by the board on 5 October 2026 · Owner: the Compliance Officer · Next review: 5 October 2027

1. Why this Code exists

Linq Africa (Pty) Ltd (“Linq Africa”) is an asset finance platform. It originates, structures and services rental and finance for movable assets across Africa, and places each programme with external funders through a dedicated special purpose vehicle. Its business depends on the trust of the manufacturers, customers and funders it works with. This Code sets out how Linq Africa conducts its business: honestly, lawfully and transparently, in every country in which it operates.

2. Who it applies to

This Code applies to Linq Africa’s directors, employees and contractors; to the members and attendees of its Investment Committee; to the special purpose vehicles it manages; and to every person who acts for Linq Africa, including its back-office service providers and referral partners, under the written terms that engage them. A person who acts for Linq Africa may not do through someone else what this Code forbids them to do themselves.

3. Our principles

3.1 We obey the law. Linq Africa complies with the laws of South Africa and of every country in which it does business. These include the Prevention and Combating of Corrupt Activities Act 12 of 2004, the Financial Intelligence Centre Act 38 of 2001, the Protection of Personal Information Act 4 of 2013 and the Companies Act 71 of 2008. Where they apply to a transaction or a counterparty, they also include the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and France’s Sapin II law.

3.2 Zero tolerance for bribery and corruption. We do not offer, promise, give, request or accept any undue advantage, directly or through anyone else, to influence a decision. We make no facilitation payments. The details are in the Anti-Bribery and Corruption Policy.

3.3 Gifts and hospitality. We give and accept only modest, occasional business courtesies that could never be read as an attempt to influence a decision. We never give or accept cash or cash equivalents, and we record what we give and receive.

3.4 Honest books and records. Every transaction is recorded accurately and in full, at its true value and on its true terms. We keep no undisclosed accounts or assets. We never issue a document with an inaccurate value to help anyone avoid duties or taxes. We are open with our accountants and auditors.

3.5 Conflicts of interest. We avoid conflicts between personal interests and Linq Africa’s interests. Where one exists, it is declared in writing and the person concerned takes no part in the decision. The details are in the Conflicts of Interest and Related Parties Policy.

3.6 Fair dealing. We tell manufacturers, customers and funders the truth about our services and their terms. We compete on the merits. We do not agree prices, divide markets or rig bids with anyone.

3.7 Third parties. We engage only reputable referral partners and service providers, after due diligence and under written terms that bind them to this Code. Their pay is reasonable for the work actually done, and it is disclosed. The details are in the Third-Party and Referral Partner Policy.

3.8 Money laundering, terrorism financing and sanctions. We know who we deal with and where money comes from. We screen our counterparties against the applicable sanctions lists. We do not take part in any transaction that would breach sanctions or export controls. The details are in the Sanctions and Export Controls Procedure.

3.9 Public officials and state-owned enterprises. Dealings with public officials, including those of airports and other state-owned or state-controlled enterprises, receive heightened care and are recorded. We make no political contributions.

3.10 Confidentiality and personal information. We protect the confidential information of Linq Africa and of everyone we work with. We process personal information only for a lawful purpose and keep it secure.

3.11 Assets. Linq Africa’s assets and information are used only for its legitimate business.

4. Speaking up

Anyone who has a concern about conduct that may breach this Code or the law should raise it with the Compliance Officer (dewald@linq.africa). A concern about the conduct of a director may be raised directly with the independent member of the Investment Committee. Concerns are handled confidentially. No one who raises a concern in good faith will suffer any retaliation, whether or not the concern turns out to be correct.

5. Breaches

A breach of this Code is examined promptly. It may lead to disciplinary action, the end of a contract, and a report to the authorities where the law requires one. For example, the Prevention and Combating of Corrupt Activities Act requires persons in a position of authority to report certain corrupt activities.

6. Acknowledgement

Every person to whom this Code applies receives a copy and acknowledges it in writing when they start, and again each year.

Published at linq.africa. Available free of charge from Linq Africa (Pty) Ltd, 290 Lyra Street, Waterkloof Ridge, Pretoria, 0081, South Africa.