Corporate Governance

Anti-Bribery Policy

The Company has adopted a zero tolerance approach to bribery.  The following is a summary of its policy:

• It is the Company’s policy to conduct all of its business in an honest and ethical manner.  The Company is committed to acting professionally, fairly and with integrity in all its business dealings and relationships where it operates.

• Directors and service providers must not promise, offer, give, request, agree to receive or accept a financial or other advantage in return for favourable treatment, to influence a business outcome or to gain any other business advantage on behalf of themselves or of the Company or encourage others to do so.

• The Company has communicated its anti-bribery policy to each of its service providers.  It requires each of its service providers to have policies in place which reflect the key principles of this policy and procedures and which demonstrate that they have adopted procedures of an equivalent standard to those instituted by the Company.

A full copy of the VCT’s anti-bribery policy and procedures can be obtained from the Company Secretary by sending an email to: unicornaimvct@iscaadmin.co.uk

Corporate Governance

The Directors of Unicorn AIM VCT plc recognise the importance of sound corporate governance and adopt the main principles of good corporate governance as set out in the Association of Investment Companies Code of Corporate Governance (the “AIC Code”).

The AIC Code addresses all of the principles set out in Section 1 of the UK Corporate Governance Code, as well as setting out additional principles and recommendations on issues that are of specific relevance to the Company. The Financial Reporting Council (FRC) has confirmed that in complying with the AIC Code the Company will meet its obligations in relation to the UK Corporate Governance Code and paragraph 9.8.6 of the Listing Rules. The Company believes that reporting against the principles of the AIC Code will provide more relevant information to shareholders than against the UK Corporate Governance Code.

The Company’s Articles of Association can be found here.

Committees

The Board as a whole considers matters relating to management engagement, nomination and remuneration. A schedule of matters reserved for the decision of the Board can be found here.

The Audit Committee comprises all of the Directors and Jeremy Hamer acts as Chairman. The Committee meets at least twice a year to review the internal financial and non-financial controls, accounting policies and contents of the Half-Yearly and Annual Reports to Shareholders. The Audit Committee has written terms of reference, which deal with its responsibilities and duties. These can be found here.

Chairman’s Tenure

The Company’s policy on the Chairman’s tenure is that any Director will serve a maximum of nine years in the role of Chairman of the Board.