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Seeking Further Guidance : Inevitably, decisions as to what is acceptable may not always be easy.

If any employee is in doubt as to whether a potential act could give rise to corruption concerns, the matter should be referred immediately to the local senior manager with responsibility for this Policy before proceeding. If necessary, guidance should also be sought from either Group Legal or Group H R. Sponsorship, Charitable and Political Donations : All ponsorship and donations made on behalf of the Group must be approved in advance by the Group !anaging "irector. Facilitation Payments : #acilitation payments are bribes and prohibited by this Policy. $hey are typically small unofficial payments paid to speed up an administrative process or secure a routine government action by an official and are most fre%uently encountered in foreign &urisdictions with perceived high corruption ris's. (here an employee )or someone acting on behalf of the Group* suspects a demand for a payment is a re%uest for a facilitation payment, this must be reported immediately to the Group olicitor. Use of Third Parties or ntermediaries +,H -o. is aware of the potential for violation of anti.corruption rules where third parties or intermediaries are involved in the transaction and will decline any re%uest of payment is in any way %uestionable. If you are as'ed to ma'e any improper payment, don/t do it. As' for help from your supervisor, legal department and report the case. 0iolations of these anti.corruption guidelines are ta'en very seriously and may be grounds for termination or other disciplinary action for any employee who1 Authori2es or participates in a violation

Improperly or negligently supervises a person who commits a violation #ail to report a violation or withholds relevant information Attempts to retaliate against an employee who reports a suspected violation.

!ecord"eeping : $he Group must 'eep accurate financial and other records and have appropriate internal controls in place which will evidence the business reason for ma'ing payments to any third parties )such as anyone who provides services for or on behalf of the Group*. 3mployees must apply the principles enshrined in this Policy in all aspects of their wor'. !esponsibilities : 3mployees must read, understand and comply with this Policy. $he Group ,oard has overall responsibility for ensuring this Policy complies with the Group4s legal and ethical obligations and to ensure everyone in the Group complies with it. $he Group olicitor and Group ecretary have primary responsibility for implementing this Policy and monitoring its effectiveness. !anagement at all levels are responsible for ensuring those reporting to them are made aware of and understand this Policy and are given ade%uate and regular training on it.

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