Anti-Bribery and Corruption Policy

Policy number: GOV02
Category: Governance

Table of Contents

1. Purpose
2. Bribery
3. Consequences of Bribery
4. Responsibility for compliance and scope of Policy
5. Facilitation payments
6. Gifts and hospitality
7. Charitable donations
8. Sponsorships, political and charitable contributions
9. Due diligence and risks
10. Conflicts of interest
11. Speaking up – reporting bribery
12. What happens if you do not comply?

1. Purpose

Two70 Digital is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations, and other requirements which govern the conduct of our operations.

2. Bribery

Bribery is defined as the giving or promising of a financial or other advantage to another party where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage is in itself improper conduct.

Bribery also includes requests or agreements to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly.

Bribery of a foreign official includes the giving or promising of a financial or other advantage intended to influence the official to obtain business or an advantage in the conduct of business, unless the official is required by law to be influenced by such advantage.

3. Consequences of Bribery

• Any person or organization guilty of bribery may face fines and/or prison terms.
• Failure to comply with this policy may result in disciplinary action, including dismissal, and legal penalties.
• The company may face fines, negative publicity, and associated damages for breaches of this policy.

4. Responsibility for Compliance and Scope of Policy

This policy applies to all employees, agents, contractors, subcontractors, consultants, business partners, and any other parties associated with the company. It is their responsibility to prevent, detect, and report bribery, in accordance with the company's whistleblowing policy.

5. Facilitation Payments

Facilitation payments are defined as small payments made to officials to expedite performance. They are considered bribes and are generally prohibited, except in cases where life is in danger, which must be reported to the directors.

6. Gifts and Hospitality

• Gifts and hospitality can be part of legitimate business, but excessive gifts may constitute bribery.
• Cash gifts are prohibited, and all gifts must be proportional and properly recorded in the Hospitality & Gifts Register.

7. Charitable Donations

Charitable donations must be fully recorded and cannot be made in cash. Donations must not be used to improperly influence any business transaction.

8. Sponsorships, Political and Charitable Contributions

The company does not make political donations and is not affiliated with any political organization. Personal donations by employees should not be presented as made on behalf of the company.

9. Due Diligence and Risks

Special care must be taken with transactions in regions known for high corruption risk, involving unusual payment methods, or where official authorization is required.

10. Conflicts of Interest

Employees must avoid conflicts of interest and should report any situations that may compromise their impartiality.

11. Speaking Up – Reporting Bribery

Employees, contractors, and third parties should report any conduct that may breach this policy to the directors or follow the whistleblowing policy.

12. What Happens if You Do Not Comply?

Failure to comply with this policy will result in disciplinary actions, and the company is committed to reporting corrupt activities to the relevant authorities.

Version: 1.0
Last updated: 16/10/2024