Anti-bribery andCorruption Policy

1. Introduction

2. Who does this policy apply to?

3. What is covered by this Policy?

4.What is Bribery and Corruption?

5. Prohibition on Bribery

6. Prohibition on Facilitation Payments

7. Red flags

8. Practical guidance

9. Countries with higher risk

10. Donations

11. Record keeping

12. Due Diligence on Suppliers, Joint Ventures, Consultants / Agents and Beneficiaries

13. Training

14. Anti-bribery Officer

15. How to raise concerns

16. Consequences for breaching this policy

17. Changes to this Policy

18. Related Policies