Anti-Bribery Policy

Martlet Capital Advisors S.L. (hereafter “MCA”) is a tied agent of Ursus-3 Capital A.V. SA a MiFID investment firm established in Spain, regulated by and registered with the Spanish Securities Market Commission – Comisión Nacional del Mercado de Valores under number 251.

MCA is fully committed to compliance with applicable anti-money laundering and counter-terrorist financing regulations. In accordance with Spanish Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing, we are required to implement appropriate measures to identify our clients, monitor business relationships, and report any suspicious transactions to the competent authorities.

These obligations form part of Spain’s regulatory framework to combat financial crime and apply to financial institutions, real estate professionals, notaries, and other designated entities. Compliance failures may result in significant sanctions.

The Firm is committed to conducting its business fairly, honestly and openly, and has a zero-tolerance approach towards bribery and corruption. The Firm has implemented a risk-based approach to identify areas where it may be at risk to bribery and has put in place systems and procedures to reduce and manage this risk.  It reserves the right not to deal with other entities that do not make the same commitment.

The Firm has adopted and implemented a number of policies and procedures which are intended to prevent the Firm, its directors, staff or agents being involved in bribery. These are reviewed regularly to ensure they remain effective. For further information on the Firm’s bribery risk policies and procedures, please contact the Compliance Officer, to whom the directors have given day-to-day responsibility for ensuring that the Firm’s anti-bribery policies and procedures are adhered to.