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Anti-bribery and
Anti-corruption Policy

Version 1.0 / 25 August 2023

1. About this Policy:

1.1. It is our policy to conduct all of our business in an honest and ethical manner in all the jurisdictions in which we operate. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

1.2. Any Arbolus employee found violating this policy will be subject to disciplinary measures, which might include termination for gross misconduct. Any third party that breaches this policy may have their contract with us terminated with immediate effect.

1.3. This policy is not a binding component of an employee's employment contract, and we retain the right to modify it whenever necessary. Regular evaluations will be conducted to ensure its effectiveness.

2. Who does it apply to?

2.1. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners (the “Relevant Persons”).

3. What is bribery?

3.1. Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. 

3.2. Bribery includes offering, promising, giving, accepting or seeking a bribe. All forms of bribery are strictly prohibited and our employees are trained in respect of this policy. The following conduct is strictly prohibited:

3.2.1. Giving or offering any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or rewarding any business received; or

3.2.2. Accepting any offer from a third party that a person knows or suspects is made with the expectation that we will provide a business advantage for them or anyone else; or

3.2.3 Giving or offering any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.

3.3. It is further strictly prohibited to threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. What is corruption?

4.1. Corruption means the abuse of a position of employment, authority, or trust to gain a business or personal benefit or advantage. It can also include making improper requests of public officials whereby the public official is asked to breach or contravene an applicable law or exceed their scope of authority.

4.2. All forms of corruption are strictly prohibited. The Relevant Persons must not engage in any practices that could be considered corrupt or that could lead to corruption.

5. Gifts and hospitality

5.1. This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

5.2. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

5.3. Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.

5.4. Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

6. Record keeping

6.1. Our employees must declare and keep a written record of all hospitality or gifts given or received. They must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy.

6.2. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. 

7. How to raise a concern

7.1. If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or the company’s Legal and Compliance Manager as soon as possible.

Version 1.0 / 25 August 2023