Anti Corruption Policy

The offer, promise or receipt of any gift, hospitality,loan, fee, reward or other advantage to induce or reward behaviour which is dishonest, illegal or a breach of trust, duty, good faith or impartiality in the performance of a person's functions or activities.

The offer or promise of any gift, hospitality, loan, fee, reward or other advantage to a public official with the intention of influencing the public official in the performance of their public function, to obtain a business advantage.

Bribery includes not only direct payments, but also authorizing or permitting an associate or third party to commit any of the acts or take any part in the actions identifies above.

It is not acceptable to:

give, promise to give, or offer, a payment, gift or hospitality to secure or award an improper business advantage;

give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate, expedite, or reward any action or procedure;

accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;

induce another individual or associate to indulge in any of the acts prohibited in the policy.

threaten or retaliate against another associate who has refused to commit a bribery offence or who has raised concerns under this policy;

give or accept any gift where such gift is or could resonably be perceived to be a contravention of this policy and / or applicable law;r

engage in any activity that might lead to a breach of this policy.

Must be duly approved. Notmal business hospitalitymust always be approved at the appropriate level of Company management.

Must not beintended to improperly influence. Associates should always assess the purpose behind any hospitality or entertainment & consider how the recipient is likely to view the hospitality. Similarly, associates must also decline any invitation or offer of hospitality or entertainment when made with the actual or apparent intent to influence their decisions.

Certain gifts are always prohibited. Some types of gifts are never acceptable including gifts that are illegal or unethical, or involve cash or cash equivalent (e.g. loans, stock options, etc). Furthermore, by way of non-exhaustive example, an invitaion to his/her family to join him on a foreign business trip, or the extension of a trip at the customer's expense to include a holiday, are at all times unacceptabel, and associates should not participate in such practices.

Modest promotional gifts are permitted. It is acceptable to offer modest promotional materials to contacts e.g. branded pens. Use of one's position with the Company to solicit a gift of any kind is not acceptable. However, the Company allows assocaites occassionally to receive unsolicited gifts of a very low intrinsic value from business contacts provided the gift is given unconditionally and not in a manner that could influence any decision-making process.

Personal payments does not cure. Associates may never pay on their personal account for gifts or hospitality in order to avoid this policy In some cultures/ countries, it may be seen as an insult to reject a gift, and refusals may adversely affect business relationships. In these circumstances, and if the gift is anything other than the moderate, the gift should be reported to the reporting manager who will decide whether such a gift can be retained or returned. If your reporting manager is uncertain, s/he should seek clarification from his/her relevant HR contact.

Gifts & Hospitality can put the Company at risk if used to facilitate unethical business practices. The Company will comply with the Anti-Corruption & Bribery Policy & Code of Conduct when giving & receiving gifts and / or hospitality. These procedures must be followed by assocaites.

The Company prohibits making or accepting, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine action by an official. Kickbacks are typically payments made in return for a business favor or advantage. All associates must avoid any activity that might lead to a facilitation payment or kickback being made or accepted.

The Company may make donations but only if they are ethical and in compliance with this policy & local applicable laws. No donation should be made which may be perceived to breach applicable law or any section of this policy. All donations must be approved by the Company & shall keep accurate records of all donations.