Anti-Bribery & Anti-Corruption Policy

Anti-Bribery and Anti-Corruption Policy. The Company has zero tolerance for bribery and corruption in any form and is committed to full compliance with the United States Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and all other applicable anti-bribery and anti-corruption laws. No director, officer, employee, agent, or representative of the Company shall, directly or indirectly: (a) offer, promise, authorize, give, or pay any bribe, kickback, or other improper payment or benefit to any person, including any government official, political party, party official, or candidate for political office, for the purpose of obtaining or retaining business or securing any improper advantage; (b) request, agree to receive, or accept any bribe or improper payment or benefit; or (c) make any facilitating or "grease" payment to any government official to expedite or secure the performance of a routine governmental action. All gifts, entertainment, hospitality, charitable donations, sponsorships, and political contributions must comply with the Company's Gift and Entertainment Policy and must be pre-approved where required. The Company shall maintain accurate books and records that fairly reflect all transactions and dispositions of assets. Third-party due diligence shall be conducted on all agents, intermediaries, consultants, and joint venture partners prior to engagement.