Our anti-bribery and corruption policy supports our zero tolerance approach to bribery and corruption.

Amongst key principles of the policy, it should be noted that:

1. The Company has a zero tolerance to bribery and corruption, the giving, receiving, offering or promising a bribe or facilitation payment are expressly prohibited;
2. Training and awareness about our zero tolerance for bribery and corruption is conducted across the Company and all relevant third parties;
3. All senior managers in the Company must commit to supporting the policy across their teams. Communication about the policy is undertaken by the CEO and the executive team;
4. Business activities must be transparent, sufficiently documented and above suspicion.

Gifts and entertainment

Customers and business associates may offer to show their appreciation by providing gifts and entertainment to employees. Accepting or offering gifts and entertainment can be problematic because it may lead others to believe that decisions have been improperly influenced. In some cases, where high-value gifts or entertainment have been offered, received, given or promised, this could be perceived as offering or accepting a bribe.

Our Gifts and Entertainment Policy and procedures are in place to ensure that employees do not offer or receive gifts or entertainment which could be seen as being inappropriate, be a breach of regulatory obligations, and/or which may give rise to actual or potential conflicts of interest.