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GROUP POLICY ON AVOIDING BRIBERY AND CORRUPTION

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Objective

The objective of this policy is to prevent and detect bribery and corruption within our organization, ensuring that we conduct business in a transparent, accountable, and fair manner.

Scope

This policy applies to all employees, directors, and representatives of the Group worldwide.

Key Principles

Avoid dealing with contractors and suppliers known or reasonably suspected to be paying bribes or being involved in corrupt activities.
Perform strict due diligence on associated persons/third parties to identify and validate their credentials and background, and confirm their suitability for the role they will be performing.
Ensure that contracts of employment reflect the provisions of this policy and make clear that disciplinary proceedings, including proceedings leading to dismissal for gross misconduct, will result if an employee is engaged in bribery or corruption.

Communication

Establish Effective Internal Communication

Ensure all employees understand the importance of preventing and detecting bribery and corruption.

Provide Regular Training Sessions

Provide regular training sessions on anti-bribery and corruption issues to all new hires and existing employees.

Make available to business partners and associated persons the principles outlined in this policy.

Responsibilities

Compliance Division

Provide guidance, support, and advice across the Group for the implementation of this policy.
Monitor and review compliance with this policy.

Organization Department

Communicate this policy to all employees and ensure that all key principles are fully incorporated in all relevant procedures.
Ensure employee awareness and understanding of this policy.

Risk Management Function

Assess all risks (both internal and external) related to bribery within the Group.
Identify and report potential corruption risks.

Internal Audit

Include this policy as an area of the Risk & Audit Universe.
Conduct regular audits to assess the adequacy and effectiveness of relevant controls.

Accountability

All personnel of the Group are responsible for complying with this policy and its related procedures.
If any employee becomes aware or suspects that an activity or conduct which has taken place could be considered a bribe or corrupt, they have a duty to report it immediately.
Any such incidents should be reported to their direct Supervisor/Line Manager or via the Whistleblowing Line.

Supporting Documentation

All relevant written communication, acknowledgements, declarations, and any other material confirming compliance with this policy are properly maintained and archived.

Review and Update

This policy will be reviewed and updated as necessary to ensure it remains effective in preventing and detecting bribery and corruption within the Group.