Updated August 27, 2025

1. Purpose

The purpose of this Procurement Policy is to ensure that Akili Ventures (“Akili”) conducts all purchasing of goods and services in a transparent, ethical, and efficient manner that delivers value-for-money, complies with applicable laws, and reflects Akili’s values of integrity, fairness, and accountability.

2. Scope

This Policy applies to all Akili employees, directors, officers, partners, and consultants (“Akili Representatives”) involved in the selection, approval, or management of vendors, suppliers, and contractors.

3. Guiding Principles

Akili is committed to:

• Transparency: Procurement processes must be fair, open, and well-documented.
• Value for Money: Balancing cost, quality, risk, and sustainability.
• Compliance: Adhering to all applicable laws and regulations, including anti-bribery, anti-corruption, anti-slavery, and AML/CTF requirements.
• Accountability: Clear responsibility for procurement decisions.
• Ethics: Avoiding conflicts of interest and ensuring equal opportunity for suppliers.

4. Procurement Process

4.1 Needs Identification

• Departments or teams must clearly define the business need, scope of work, and budget before engaging suppliers.

4.2 Supplier Screening and Due Diligence