Anti-Bribery and Corruption Policy

It is the Company’s policy to conduct all business in an honest and ethical manner. A zero-tolerance approach is taken to bribery and corruption and we (the ‘Company’) are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

The purpose of this policy is to:

• Set out the Company’s responsibilities, and the responsibilities of those working for the Company, in observing and upholding our position on bribery and corruption; and
• Provide information and guidance to those working for the Company on how to recognise and deal with bribery and corruption issues.

This policy applies to all employees (whether permanent or fixed term) based in any country and extends to consultants, contractors, trainees, seconded staff, home workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person working for the Company, or any of its subsidiaries or their employees, wherever located.