This document outlines the policies and procedures set forth by Grin Studios Limited to ensure ethical, legal, and professional standards are maintained across all operations and interactions. These policies apply to all employees, contractors, and partners engaged with Grin Studios Limited.

1. Financial Procedures

Purpose — To ensure accuracy, transparency, and integrity in the organization's financial management and reporting.

Scope — Covers all financial transactions, including accounting, billing, and auditing.

Key Policies —

Adherence to Generally Accepted Accounting Principles (GAAP): All financial statements will be prepared in accordance with GAAP to ensure consistent and reliable reporting.

Transparent Financial Reporting: Grin Studios Limited will provide timely and transparent financial reports to relevant stakeholders, including investors, creditors, and management.

Roles and Responsibilities —

Chief Financial Officer (CFO): Responsible for overseeing the organization's financial management, reporting, and compliance with accounting standards.

Finance Department: Responsible for recording financial transactions, preparing financial statements, and assisting with internal controls.

Management: Responsible for reviewing financial reports and ensuring compliance with financial policies.

External Auditors: Independent third-party professionals engaged to provide an objective assessment of the organization's financial statements.

Compliance Mechanisms —

Regular review of financial controls by internal audit and management.

Comparison of financial statements to industry benchmarks and best practices.

2. Anti-Fraud

Purpose — To prevent, identify, and address fraud within the organization.

Scope — Applies to all forms of fraud affecting the organization, including asset misappropriation, fraudulent financial reporting, and billing schemes.

Key Policies —

Zero Tolerance for Fraud: Grin Studios Limited has a zero-tolerance policy for any fraudulent activity and will take appropriate disciplinary action, which may include termination of employment and legal prosecution.

Mechanisms for Reporting Suspected Fraud: The company provides various confidential channels for employees to report suspected fraud, such as a dedicated hotline, email address, or online reporting system.

Investigation and Disciplinary Procedures for Fraudulent Activities: Allegations of fraud will be promptly investigated and addressed through a fair and consistent disciplinary process.

Roles and Responsibilities —

Management: Responsible for fostering a culture of honesty and ethical conduct, promoting awareness of fraud risks, and implementing effective anti-fraud controls.

Employees: Responsible for reporting any suspected fraudulent activity and adhering to the organization's financial and accounting policies.

Internal Audit: Responsible for identifying and investigating potential fraud risks and irregularities.

Compliance Mechanisms:

Implementation of a robust internal control framework to prevent fraudulent activities.

Regular training for employees on fraud awareness, detection, and prevention.

Establishing a clear and transparent whistleblowing policy.

3. Bribery and Corruption

Purpose — To prohibit bribery and corrupt practices in all business dealings.

Scope — Includes all employees and business transactions, both domestic and international.

Key Policies —

Compliance with the Foreign Corrupt Practices Act (FCPA) and similar regulations: Grin Studios Limited strictly complies with the FCPA and all applicable anti-bribery and anti-corruption laws and regulations.

Strict No-Bribery Policy: Offering, promising, authorizing, or giving anything of value to obtain an improper business advantage is strictly prohibited.

Training on Recognizing and Avoiding Bribery and Corruption: The company provides regular training to employees on recognizing and avoiding bribery and corruption risks in various business situations.

Roles and Responsibilities —

Management: Responsible for setting the tone at the top by demonstrating ethical leadership and ensuring compliance with anti-bribery and anti-corruption laws.

Compliance Officer: Responsible for overseeing the implementation of the anti-bribery and anti-corruption program and providing guidance to employees.

Employees: Required to understand and comply with the company's anti-bribery and anti-corruption policy and avoid any actions that could constitute bribery or corruption.

Compliance Mechanisms —

Conducting due diligence on business partners and third-party vendors.

Maintaining clear and transparent financial records.

Implementing a system for reporting and investigating potential violations of the anti-bribery and anti-corruption policy.

4. Whistleblowing

Purpose — To provide a safe and confidential means for reporting wrongdoing.

Scope — Covers all types of misconduct, including illegal, unethical, or unsafe practices.

Key Policies —

Protection for Whistleblowers from Retaliation: Grin Studios Limited prohibits retaliation against employees who report suspected wrongdoing in good faith.

Anonymous Reporting Channels: The company offers multiple anonymous reporting channels for employees to report suspected wrongdoing, such as a dedicated hotline, email address, or online reporting system. These channels are managed by an independent third party to ensure anonymity and confidentiality.

Investigation and Response Protocol for Reported Concerns: All reported concerns will be promptly investigated by a designated team, and appropriate corrective action will be taken based on the findings. The reporting individual will be kept informed of the investigation process and outcome to the extent possible, while maintaining confidentiality.

Roles and Responsibilities —

Management: Responsible for creating and maintaining a culture of open communication and trust, where employees feel comfortable raising concerns without fear of retaliation.

Compliance Officer: Responsible for overseeing the whistleblowing program, receiving and managing reported concerns, and coordinating investigations.

Employees: Responsible for reporting any suspected wrongdoings in good faith through the designated channels.

Compliance Mechanisms:

Regularly communicating the whistleblowing policy to all employees and providing training on its procedures.

Conducting independent investigations into reported concerns and taking appropriate disciplinary action where necessary.

Monitoring and evaluating the effectiveness of the whistleblowing program and making improvements as needed.

5. Conflict of Interest

Purpose — To identify, disclose, and manage conflicts of interest that may arise between personal and professional interests.

Scope — Applies to situations where personal interests of an employee, contractor, or business partner could influence their professional judgment or actions, potentially harming the organization's interests.

Key Policies —

Mandatory Disclosure of Potential Conflicts: Employees, contractors, and business partners are required to disclose any potential conflicts of interest to the relevant manager or compliance officer immediately upon their identification.

Procedures for Managing Conflicts: Identified conflicts will be managed through various means, such as recusal from decision-making processes, divestment of conflicting interests, or establishing appropriate safeguards to mitigate potential harm.

Restrictions on Participation in Decision-Making When Conflicts Exist: Individuals with conflicts of interest will be restricted from participating in decision-making processes that could be influenced by their personal interests.

Roles and Responsibilities —

Employees, Contractors, and Business Partners: Responsible for disclosing potential conflicts of interest and avoiding situations that could create conflicts.

Managers: Responsible for receiving disclosures and managing conflicts within their teams.

Compliance Officer: Responsible for providing guidance on identifying and managing conflicts of interest, and maintaining a register of declared conflicts.

Compliance Mechanisms —

Regular training for employees, contractors, and business partners on identifying and disclosing conflicts of interest.

Maintaining a clear and accessible policy on conflict of interest, outlining disclosure and management procedures.

Periodic review of declared conflicts by the compliance officer and management.

6. Modern Slavery

Purpose — To prevent modern slavery and human trafficking within the organization and its supply chains.

Scope — Covers all business operations and supply chains, both domestically and internationally.

Key Policies —

Compliance with the Modern Slavery Act and Similar Legislation: Grin Studios Limited is committed to complying with all relevant modern slavery legislation and ensuring its operations are free from the risks of forced or compulsory labor.

Due Diligence Procedures for Suppliers: The company will implement due diligence procedures to identify and assess modern slavery risks within its supply chains. This includes risk assessments, supplier audits, and contractual provisions addressing modern slavery.

Training on Recognizing and Preventing Modern Slavery: The company will provide training to relevant employees and suppliers on recognizing signs of modern slavery and procedures for reporting suspected instances.

Roles and Responsibilities —

Management: Responsible for setting high ethical standards and implementing measures to prevent modern slavery within the organization and its supply chains.

Procurement and Supply Chain: Responsible for conducting due diligence on suppliers and ensuring compliance with policies.

Employees: Expected to be aware of the signs of modern slavery and report any concerns through appropriate channels.

Compliance Mechanisms —

Conducting regular risk assessments of the supply chain.

Including anti-slavery clauses in supplier contracts.

Monitoring and auditing supply chains for potential risks.

7. Health and Safety

Purpose — To ensure a safe and healthy work environment for all employees, contractors, and visitors, and to protect them from work-related injury and illness.

Scope — Includes all workplaces, activities, equipment, and work processes.

Key Policies —

Compliance with Occupational Health and Safety Regulations: Grin Studios Limited will strictly adhere to all applicable health and safety legislation, regulations, and industry standards.

Hazard Identification and Risk Assessment: The company will regularly conduct hazard identification and risk assessments to identify potential hazards and implement appropriate control measures.

Safe Work Procedures: Safe work procedures and protocols will be developed and documented for all potential hazardous tasks and processes.

Procedures for Reporting and Addressing Safety Concerns: The company will implement clear and accessible procedures for employees to report any health and safety concerns and ensure that those concerns are promptly investigated and addressed.

Provision of Personal Protective Equipment (PPE): The company will provide and maintain appropriate PPE where necessary, and ensure employees are trained in its proper use.

Emergency Preparedness: Emergency plans and procedures will be developed, communicated, and regularly practiced to ensure effective responses in the event of accidents, incidents, or natural disasters.

Incident Reporting and Investigation: All accidents, incidents, and near-misses will be promptly reported, investigated, and corrective actions taken to prevent reoccurrence.

Roles and Responsibilities —

Management: Responsible for developing, implementing, and overseeing the health and safety program, and providing the necessary resources.

Health and Safety Committee/Representative: Responsible for providing advice on safety and health matters, developing safety procedures, and monitoring compliance.

Employees: Required to comply with safety procedures, report hazards, participate in safety training, and use PPE as required.

Compliance Mechanisms —

Regular workplace inspections and audits to identify and address potential hazards.

Training and education programs for employees on health and safety practices.

Maintenance of records related to workplace health and safety, including training, incidents, and inspections.

8. Data Protection

Purpose — To protect personal data and ensure compliance with privacy laws and regulations.

Scope — Applies to the collection, use, storage, and disclosure of personal data, such as customer information, employee records, and business partner data.

Key Policies —

Compliance with GDPR and Other Data Protection Laws: Grin Studios Limited will comply with all relevant data protection laws and regulations, including the General Data Protection Regulation (GDPR).

Data Privacy Notices and Consent Procedures: The company will provide clear data privacy notices and obtain necessary consent from individuals before collecting, using, or disclosing personal data.

Data Breach Notification Processes In the event of any suspected data breach, protocols will be in place to contain the breach, assess the impact, notify the relevant data protection authorities and affected individuals as mandated.

Roles and Responsibilities —

Data Protection Officer: Responsible for overseeing compliance with data protection laws, data management practices, and handling data access requests.

Managers: Responsible for implementing data protection measures within their teams.

Employees: Required to handle personal data responsibly, in accordance with policies and training.

Compliance Mechanisms —

Implementation of technical and organizational security measures to protect personal data.

Regular privacy training for employees.

Periodic audits of data management practices.

9. Ethics

Purpose — To uphold high ethical standards in all organizational activities.

Scope — Covers all employees and aspects of business conduct, including interactions with customers, suppliers, partners, and communities.

Key Policies —

Code of Ethics: Grin Studios Limited will maintain a comprehensive Code of Ethics outlining the ethical principles and values guiding organizational behavior and decision-making.

Training on Ethical Decision-Making: Employees will receive training on the Code of Ethics and ethical decision-making frameworks to equip them to navigate ethical dilemmas.

Mechanisms for Reporting Unethical Behavior: The company will provide accessible channels for reporting ethical concerns and ensure thorough investigation of any reported unethical behavior.

Roles and Responsibilities —

Board of Directors and Management: Responsible for setting the ethical tone, modeling ethical behavior, and enforcing the Code of Ethics.

Employees: Expected to adhere to the Code of Ethics and act with integrity.

Compliance Mechanisms —

Integration of ethical considerations into decision-making processes.

Regular communication and reinforcement of ethical expectations.

Disciplinary procedures for ethical violations.

10. Research Governance and Integrity

Purpose — To ensure integrity and ethical standards in research activities and to promote responsible conduct of research.

Scope: Applies to all research undertaken by the organization, including research involving human subjects, animal subjects, and sensitive data.

Key Policies —

Adherence to Research Ethics and Standards: Grin Studios Limited will conduct research in accordance with recognized ethical standards, relevant professional guidelines, and applicable laws and regulations.

Review and Approval Processes for Research Projects: Research projects will be reviewed and approved by an appropriate research ethics committee or board to assess ethical implications and ensure compliance.

Informed Consent: Where relevant, informed consent will be obtained from human research participants.

Data Management and Publication Ethics: The company will adhere to responsible data management practices and publish research findings in a complete, unbiased, and transparent manner.

Roles and Responsibilities —

Researchers: Responsible for conducting research ethically, adhering to research standards, and obtaining regulatory and ethical approvals as necessary.

Research Ethics Committee/Board: Responsible for reviewing research proposals, ensuring ethical considerations are addressed, and monitoring ongoing research activities.

Management: Responsible for supporting a culture of research integrity, providing resources for compliance, and addressing research misconduct.

Compliance Mechanisms —

Training on research ethics and responsible conduct of research for researchers and relevant staff.

Regular assessment and monitoring of research projects for ethical adherence.

Established procedures for reporting and investigating research misconduct.

11. Environment

Purpose — To minimize the environmental impact of the organization's activities and strive towards sustainable practices.

Scope — Includes all operational aspects affecting the environment, such as energy use, waste generation, resource consumption, and pollution.

Key Policies —

Environmental Sustainability Goals: Grin Studios Limited will establish clear environmental sustainability goals and implement strategies to achieve them.

Compliance with Environmental Regulations: The company will adhere to all applicable environmental laws and regulations.

Initiatives for Reducing Carbon Footprint and Waste: The company will implement initiatives to conserve energy, optimize resource use, reduce waste generation, and promote recycling and responsible disposal practices.

Roles and Responsibilities —

Management: Responsible for setting environmental sustainability goals, developing plans, allocating resources, and monitoring progress.

Sustainability Committee/Officer: Responsible for developing and implementing environmental policies, assessing environmental impacts, and promoting environmental awareness.

Employees: Expected to comply with environmental policies, make conscious choices in resource use, and participate in sustainability initiatives

Compliance Mechanisms —

Assessment of the organization's environmental footprint.

Regular environmental training and awareness programs for employees.

Monitoring and reporting on environmental performance against targets.

12. IT

Purpose — To ensure the security, availability, and integrity of IT systems and data, protecting them from unauthorized access, use, disclosure, disruption, modification, or destruction.

Scope — Covers all IT infrastructure, systems, and data management practices.

Key Policies —

IT Security Protocols: Grin Studios Limited will implement robust IT security policies and protocols to manage access controls, data encryption, threat detection, and incident response.

Data Backup and Disaster Recovery Plans: The company will maintain comprehensive data backup and disaster recovery plans to ensure data integrity and business continuity in the event of disruptions.

Acceptable Use Policy for IT Resources: The company will establish an Acceptable Use Policy outlining appropriate and prohibited use of IT systems, networks, and data.

Roles and Responsibilities —

IT Department: Responsible for designing, implementing, and maintaining security measures, and responding to security incidents.

Management: Responsible for providing resources and support for IT security, and setting expectations for secure IT practices.

Employees: Required to comply with IT security policies, report IT security issues, and use IT resources responsibly.

Compliance Mechanisms —

Regular vulnerability assessments and penetration testing of IT systems.

Employee training on IT security awareness and best practices.

Monitoring and auditing of IT systems for compliance.

13. Safeguarding

Purpose: To protect individuals, specifically children, young people, or vulnerable adults, from harm, abuse, and neglect within the organization's sphere of influence.

Scope: Applies to all situations where employees or contractors interact with vulnerable groups or where the organization's activities might have an impact on their safety and well-being.

Key Policies —

Safeguarding Procedures and Reporting Mechanisms: Grin Studios Limited will develop and implement clear safeguarding procedures, including mechanisms for reporting and responding to concerns or allegations of abuse or neglect.

Training on Recognizing and Responding to Safeguarding Issues: The company will provide safeguarding training to employees and relevant stakeholders to help them identify signs of abuse or neglect and follow appropriate reporting protocols.

Compliance with Relevant Safeguarding Laws and Standards: The company will adhere to applicable laws, regulations, and professional standards related to safeguarding.

Roles and Responsibilities —

Management: Responsible for establishing a safeguarding culture, developing and implementing policies, and ensuring compliance.

Safeguarding Officer: Designated to oversee safeguarding procedures, provide advice and guidance, and manage safeguarding concerns within the organization.

Employees: Expected to be aware of safeguarding issues, report concerns, and act in the best interests of vulnerable groups.

Compliance Mechanisms —

Pre-employment screening practices for roles that involve working with vulnerable groups.

Collaboration with external agencies or authorities in the investigation and response to safeguarding concerns.

Regular review and updates to safeguarding policies and procedures.