G.A. Farrell & Associates Limited (”GAF&A”) is committed to maintaining industry standards, best practice and ethics. In this regard, this policy exists so that GAF&A and those who work for the company observe and uphold a zero-tolerance position on bribery and corruption.

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POLICY STATEMENT

GAF&A is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. GAF&A’s zero- tolerance for bribery and corrupt activities means it is committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

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GAF&A will constantly uphold all laws relating to anti-bribery and corruption, in particular, Prevention of Corruption Act 11:11 as amended.

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GAF&A recognises that bribery and corruption are punishable on conviction on indictment to a fine of twenty thousand dollars and to imprisonment for two years or on summary conviction to a fine of two thousand dollars and to imprisonment for four months.

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DEFINITION OF BRIBERY

1. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

2. A bribe refers to any inducement, reward, or object/item or value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

3. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

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WHAT IS AND WHAT IS NOT ACCEPTABLE

This section of the policy is sub-divided into four (4) areas:

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1. Gifts and hospitality

   • GAF&A accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

     • It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

     • It is not made with the suggestion that a return favour is expected.

     • It is in compliance with local law.

     • It is given in the name of the company, not in an individual’s name.

     • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

     • It is appropriate for the circumstances \e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).

     • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.

     • It is given/received openly, not secretly.

     • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

     • It is not above a certain excessive value, as pre-determined by the company‘s compliance manager.

     • It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

     • Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

     • GAF&A recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

     • As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

     • The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

2. Facilitation payments and kickbacks

   • GAF&A does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

   • GAF&A does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

   • GAF&A recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

     • Keep any amount to the minimum.

     • Ask for a receipt, detailing the amount and reason for the payment.

     • Create a record concerning the payment.

     • Report this incident to your line manager.

3. Political contributions

   • GAF&A will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

4. Charitable contributions

   • GAF&A accepts the act of donating to charities — whether through services, knowledge, time, or direct financial contributions (cash or otherwise) — and agrees to disclose all charitable contributions it makes.

   • Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

   • We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.