Anti-Bribery and Anti Corruption Policy

Company Letterhead

{{company_name}}

{{company_address}}

Phone: {{phone}}

Email: {{email}}

Website: {{website}}

1. Introduction and Policy Statement

{{company_name}} (the “Company”) is committed to conducting its business ethically, honestly, and with integrity. The Company has a zero-tolerance approach to bribery and corruption and is committed to upholding all applicable laws relevant to countering bribery and corruption in all the jurisdictions in which it operates, including but not limited to, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA) 1977, and local anti-corruption laws.

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, consultants, business partners, or any other person associated with us (collectively referred to as “Associated Persons”).

2. What is Bribery and Corruption?

Bribery involves offering, promising, giving, accepting, or soliciting anything of value to improperly influence a business outcome or gain an unfair advantage. Corruption is the abuse of entrusted power for private gain.

This includes, but is not limited to:

- Direct and indirect payments or gifts.

- Kickbacks, facilitation payments, or unearned income.

- Excessive hospitality or entertainment.

- Undue political or charitable contributions.

- Misuse of company assets.

- Conflicts of interest where personal interests improperly influence business decisions.

3. Gifts and Hospitality

Associated Persons must not offer, give, or accept gifts or hospitality to or from third parties if it could be perceived to improperly influence a business decision or create an obligation. Gifts and hospitality should always be modest, reasonable, and proportionate, and must be approved by {{approving_manager}}.

All gifts and hospitality, irrespective of their value, offered or received must be recorded in the Company’s Gifts and Hospitality Register. Gifts exceeding {{gift_value_limit_currency}} {{gift_value_limit}} require prior written approval from {{senior_management_approval_role}}.

Promotional gifts of low value (e.g., branded pens, calendars) that are not intended to influence business decisions are generally acceptable.

4. Facilitation Payments

Facilitation payments, also known as 'grease payments', are small payments or tips made to secure or speed up the performance of a routine governmental action. The Company strictly prohibits facilitation payments, even if they are common practice in certain countries. Payments made under duress or threat to personal safety must be immediately reported to {{reporting_contact}}.

5. Political Contributions

The Company does not make direct or indirect political contributions to political parties, organizations, or individuals engaged in politics. Any exceptions require explicit written approval from the Board of Directors/{{board_approval_role}}.

6. Charitable Contributions and Sponsorships

All charitable donations and sponsorships must be legitimate and made in accordance with the Company’s internal policies and procedures. Due diligence must be conducted to ensure that contributions are not used as a conduit for bribery. All charitable contributions and sponsorships must be approved by {{approving_authority}}.

7. Due Diligence on Third Parties

The Company will conduct appropriate due diligence on all third parties (e.g., agents, distributors, joint venture partners, suppliers) acting on its behalf to ensure they share the Company's commitment to anti-bribery and anti-corruption. Contracts with third parties must include anti-bribery and anti-corruption clauses.

8. Raising Concerns and Whistleblowing

Associated Persons are encouraged to report any suspected instances of bribery or corruption without fear of retaliation. All reports will be treated with confidentiality. Concerns should be reported to {{reporting_officer}} or through the Company’s whistleblowing hotline/platform at {{whistleblowing_contact_details}}.

The Company will investigate all reports promptly and fairly.

9. Training and Awareness

All Associated Persons will receive appropriate training on this policy and their responsibilities in preventing bribery and corruption. Refresher training will be provided regularly, at least every {{training_frequency_months}} months.

10. Monitoring and Review

The Company’s internal controls and compliance measures will be regularly monitored and reviewed to ensure their effectiveness in preventing and detecting bribery and corruption. This policy will be reviewed at least annually by {{review_authority}} and updated as necessary.

11. Consequences of Non-Compliance

Breaches of this policy will lead to disciplinary action, up to and including termination of employment or contract. Serious breaches may also result in criminal prosecution and significant penalties under applicable anti-bribery and anti-corruption laws.

Signature Block

___________________________

Signature: {{authorised_signatory_name}}

Title: {{authorised_signatory_title}}

Date: {{date}}