1st January 2016

To our stakeholders:

I am pleased to confirm that Gapuma UK Ltd reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Amit Parekh
Director

HUMAN RIGHTS
2.1 Gapuma Uk Ltd is vehemently opposed to the use of slavery in all forms; cruel,
inhuman or degrading punishments; and any attempt to control or reduce
freedom of thought, conscience and religion.
2.2 Gapuma UK Ltd will ensure that all of its employees, agents and contractors are
entitled to their human rights as set out in the Universal Declaration of
Human Rights and the Human Rights Act 1998.
2.3 Gapuma UK Ltd will not enter into any business arrangement with any person,
company or organisation which fails to uphold the human rights of its workers
or who breach the human rights of those affected by the organisation’s
activities.

All employees have been made aware of Gapuma UK Ltd's policy in this area and have been required to read and familiarise themselves with this policy.

All policy documents are available to access at any time via the company's server and employees are encouraged to submit suggestions, feedback and any concerns through the listed individuals with special responsibility and oversight in this area.

2012 was the first year that Gapuma UK Ltd formally recorded its fundamental beliefs and standards in regards to Human Rights. The Human Rights I Ethical policy was formally drafted, reviewed and opened to all employees for feedback, before being authorised by the Managing Director. This first step in formalising Gapuma's position has ensured that all employees were encouraged to consider the issues central to Human Rights and to enter into discussion with each other in relation to this.
This policy, and the results of this policy are subject to ongoing review by Senior Management

3.1 Gapuma UK Ltd is committed to complying with all relevant employment
legislation and regulations. Gapuma UK Ltd regards such regulations and
legislation as the minimum rather than the recommended standard. 3.2 No worker should be discriminated against on the basis of age, gender, race,
sexual orientation, religion or beliefs, gender reassignment, marital status or
pregnancy. All workers should be treated equally. Workers with the same
experience and qualifications should receive equal pay for equal work. 3.3 Workers should be aware of the terms and conditions of their employment or
engagement from the outset. In particular workers must be made aware of
the wage that they receive, when and how it is to be paid, the hours that they
must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick
leave, maternity I paternity leave and such other leave as is granted by legislation as a minimum.
3.4 Gapuma UK Ltd does not accept any corporal punishment, harassment in any
form, or bullying in any form.

All employees have been made aware of Gapuma UK Ltd's policy in this area and have been required to read and familiarise themselves with this policy.
All policy documents are available to access at any time via the company's server and employees are encouraged to submit suggestions, feedback and any concerns through the listed individuals with special responsibility and oversight in this area.

2012 was the first year that Gapuma UK Ltd formally recorded its fundamental beliefs and standards in regards to Workers Rights. The Workers Rights policy was formally drafted, reviewed and opened to all employees for feedback, before being authorised by the Managing Director. This first step in formalising Gapuma's position has ensured that all employees were encouraged to consider the issues central to Workers Rights and to enter into discussion with each other in relation to this. As part of our participation and adoption of ISO 9001 we hold Quartlery Management Review Meetings where representatives from each department report back on the thoughts, feeling and opinions of all employees and ensure that feedback is recorded and considered as appropriate.

4.1 Gapuma UK Ltd is committed to keeping the environmental impact of its
activities to a minimum and has established an Environmental Policy in order
help achieve this aim.
4.2 As an absolute minimum, Gapuma UK Ltd will ensure that it meets all applicable
environmental Jaws in whichever jurisdiction it may be operating.

• 1.POLICY AIMS
We endeavor to:
Comply with and exceed all relevant regulatory requirements. Continually improve and monitor environmental performance. Continually improve and reduce environmental impacts. Incorporate environmental factors into business decisions.
Increase employee awareness and training.
2. PAPER
We will minimise the use of paper in the office.
We will reduce packaging as much as possible.
We will seek to buy recycled and recyclable paper products.
We will reuse and recycle all paper where possible.
3. ENERGY AND WATER
We will seek to reduce the amount of energy used as much as possible.
Lights and electrical equipment will be switched off when not in use. Heating will be adjusted with energy consumption in mind.
The energy consumption and efficiency of new products will be taken into account when
purchasing.
4. OFFICE SUPPLIES
We will evaluate if the need can be met in another way.
We will evaluate if renting/sharing is an option before purchasing
equipment.
We will evaluate the environmental impact of any new products we
intend to purchase.
We will seek to buy more environmentally friendly and efficient
products.
We will reuse and recycle everything we are able to.
5. TRANSPORTATION
We will reduce the need to travel, restricting to necessity trips only.
We will promote the use of travel alternatives such as e-mail or
video/phone conferencing.
We will make additional efforts to accommodate the needs of those
using public transport
or bicycles.
We will use the 'green' vehicles and maintain them rigorously.
6. MAINTAINANCE AND CLEANING
Cleaning materials will be as environmentally friendly as possible.
Materials used in office refurbishment will be as environmentally
friendly as possible.
We will only use licensed and appropriate organisations to dispose of waste.
7. MONITORING AND IMPROVING
We will comply with and exceed all relevant regulatory requirements. We will continually improve and monitor environmental performance. We will continually improve and reduce environmental impacts.
We will incorporate environmental factors into business decisions.
We will Increase employee awareness through training.
8. CULTURE
We will involve staff in the implementation of this policy, for greater
commitment and
improved performance.
We will update this policy at least annually in consultation with staff
and other stakeholders
where necessary.
We will provide staff with relevant environmental training.
We will work with suppliers, contractors and sub-contractors to improve their
environmental performance.
We will use local labour and materials where available to reduce C02 and help the
community.

2012 was the first year that Gapuma UK Ltd formally recorded its
fundamental beliefs and standards in regards to Environmental Policy. The Environmental policy was formally drafted, reviewed and opened to all employees for feedback, before being authorised by the
Managing Director. This first step in formalising Gapuma's position has ensured that all employees were encouraged to consider the issues
central to conservation of the envirnonment and to enter into
discussion with each other in relation to this.
This policy, and the results of this policy are subject to ongoing review by Senior Management.

• 1. CODE OF ETHICS, ANTI-BRIBERY AND BUSINESS CONDUCT POLICY
Throughout this document Company refers to Gapuma Group Limited, Gapuma (UK) Limited
and Gapuma Enterprises Limited.
2. POLICY
The Company is committed to conducting all of its business in an
honest and ethical manner
and has adopted this Policy to:
• promote honest and ethical conduct;
• ensure compliance with applicable laws, rules and regulations; and
• evidence its commitment to bribery prevention and the carrying out of business fairly,
honestly and openly.
All Personnel have a responsibility to obey the law and act ethically
and properly in compliance
with this Code and Policy.
This Code and Policy is a guide that is intended to alert Personnel to the significant legal and
ethical issues that can arise, the mechanisms available to report illegal or unethical conduct, the
consequences of breaking the Code and Policy, and the actions the Company will take to ensure
other Associated Persons comply with this Code and Policy, in
particular the prevention of
bribery.
It is not a comprehensive document that addresses every legal or
ethical issue that may
confront Personnel, nor is it a summary of all laws and policies that
apply to the business of the
Company. This Code and Policy should help Personnel to decide how to act. It should be used
as a guide by Personnel to the way they work. If Personnel come
across anything on Company
business they are not sure about because it seems wrong and they
need advice, then the Board
requires Personnel to raise the issue in accordance with this Code and Policy. The Company is
committed to creating an environment where Personnel can raise these issues without fear of
retaliation.
The Company is committed to working only with third parties, including agents,
representatives, advisers, contractors, suppliers, intermediaries and joint venture partners,
whose business ethics and behaviours are consistent with this Code and Policy.
APPLICATION
This Policy applies to all Personnel. The Managing Director is responsible for monitoring
compliance with this Policy. The provisions of this Policy are mandatory and full compliance by
all Personnel is required under all circumstances. Failure to comply with this Policy can have
severe consequences for both individual Personnel and the Company. The Company will impose
appropriate disciplinary measures, up to and including dismissal, for breaches of this Policy.
All Personnel who believe they have experienced or witnessed unethical behaviour on the
Company's business have a responsibility to do something about it. Their concerns should be
raised with their manager or, if not appropriate, the Managing Director. Provided concerns
are reported in good faith, Personnel will not be penalised in anyway if these are unfounded
or mistaken.
5. GOVERNING PRINCIPLES
All Personnel must:(a) apply the Company's policy of honesty, integrity and ethical conduct to everything the
Company does;
(b) take personal responsibility for implementing the provisions of this Code and Policy;
(c) comply with applicable laws, regulations and contract requirements as a minimum and
the Company's own standards where these are higher; and
(d) seek guidance where unsure of the appropriate course of action. The Managing Director will:
(a) act ethically, applying the same high standards of conduct expected throughout the
Company;
(b) promote ethical conduct within the Company and on its business;
( c) provide training and appropriate support to Personnel to equip them to deal with
ethical issues;
(d) listen to concerns expressed by Personnel about business conduct and support them in
expressing those concerns; and
(e) ensure that no Personnel face retaliation for reporting suspected misconduct.
.CONFLICTS OF INTEREST
Personnel must avoid situations where they have or appear to have (or could potentially have
or appear to have) a conflict of interest between their own interests and the best interests of
the Company. If such a situation arises, Personnel must promptly
disclose in writing to the
Managing Director the relevant facts and circumstances that create (or could create) the
conflict of interest.
For the purposes of this Policy, and in addition to those matters
specifically prohibited, conflicts
of interest include (but are not limited to) situations in which Personnel act in any manner
which might result in or create the appearance of using their
relationship with the Company for
private gain or for the benefit of another person, corporation,
partnership or other entity,
including any competitor, or where Personnel's duties to one or more entities are likely to be at
odds with each other or incompatible.
In particular, Personnel must not, directly or indirectly:engage in any personal business transaction or private arrangement for personal profit
or the benefit of another person or entity or for the benefit of a
competitor, which:rises out of their association with the Company and/or uses its
corporate
property, information or position;
o may be based upon confidential or non-public Company information; or
o interferes with the performance of their obligations to the Company;
• act in any manner which involves the Company, in which the
Personnel have a personal
interest and which is incompatible or inconsistent with their obligations to the
Company;
• influence negotiations or transactions between the Company and its agents,
intermediaries, representatives, advisers, suppliers, contractors,
clients, joint.·venture
partners or other parties for personal gain or have any financial interest in contracts
awarded by the Company other than their contract of employment or
the consulting or
other contract under which they provide services to the Company;
• hold positions or jobs or engage in outside businesses or other
interests that adversely
impact the performance of duties owed to the Company without the
prior written
consent of the Managing Director;
• put themselves in a position where any of their family relations is
employed by or acts as a contractor or consultant to the Company and reports to them;• serve on the board of directors or similar body of a competitor of the Company or act in
any other capacity for a competitor of the Company;
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• serve on the board of directors of any publicly traded company without the prior
written consent of the Managing Director; or
• take for themselves personally, or for their family relations, opportunities that properly
belong to the Company or are discovered through the use of its corporate property,
information or property. BUSINESS CONDUCT
Fraud, Deception and Dishonesty
The Company and its Personnel must not defraud anyone or actdishonestly. Personnel must do
their best to protect the Company from fraud at all times and be alert to the possibility of fraud
or dishonesty in the Company's business.
Work Environment
The Company strives to maintain a work environment free of discrimination, harassment and
bullying in which diversity is welcomed and in which individuals are accorded equality of
employment opportunity on merit-based on work performance and potential ability.
Employment includes not only equal treatment in hiring, but also equal treatment in
promotion, training, compensation, termination and disciplinary action. The Company does not discriminate and will not accept in its business any discrimination on the
grounds of race, colour, nationality, ethnic or national origin, religion or belief (including
political affiliation), age, gender, sexual orientation, gender reassignment, marital or civil
partner status, pregnancy or maternity, disability.
It is the responsibility of all Personnel to contribute to a work atmosphere free of harassing,
abusive, disrespectful, disorderly, disruptive or other non-professional conduct. The Company
will not tolerate behaviour that makes other Personnel feel inferior, humiliated, upset or
th re ate ned.
Recording of Transactions and Reporting of Financial Information
The integrity of the Company's record keeping and reporting system shall be maintained at all
times and the Company's books and records must fully and fairly disclose, in a complete
accurate, timely and understandable manner, all transactions and dispositions of the assets of
the Company. The Company's system of internal financial controls and delegated authorities
must be followed.
Record Retention and Destruction
Company records and documents must be retained for appropriate periods in order to meet
local statutory requirements and the Company's business needs. Upon expiration of the
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relevant retention period, permission should be obtained from Managing Director to destroy
the records and documents.
Employee Privacy and Personal Information
Personal information and data will be handled appropriately by the Company, which will
protect individual privacy and follow the data privacy laws in the countries in which it operates.
Personal information of directors, officers, employees, contractors and consultants may be
collected only to the extent that is necessary for business, legal, security or contractual
purposes and collection of personal information is to be conducted by fair and lawful means
with the knowledge and consent of the individual from whom the information is being
collected. Access to employee personal records and the information contained therein shall be
limited to those with a need to know for a legitimate business purpose. Personal information
shall be retained by the Company for only as long as it is required by the Company and shall
thereafter be destroyed. The Company will not transfer personal information to other countries
if this is not allowed by local law.
Confidential Information
Personnel must not use or disclose (except in the proper course of their duties) the Company's
confidential information (including trade secrets, financial sales and marketing information,
intellectual property, know-how, records, data, plans, strategies, processes, business
opportunities, customers, suppliers, employees and all personal information relating to
Personnel). This may only be disclosed to third parties if the disclosure is appropriately
authorised by Managing Director and on a confidential basis.
Under no circumstances should Personnel discuss confidential information in a public place, or
disclose confidential information from a previous employer to the Company, unless permitted.
Intellectual Property
All information, technology and intellectual property developed by Personnel arising out of or
in connection with the employment or appointment by the Company belongs to the Company,
and all Personnel must assign to the Company all rights they may have in any such information, technology and intellectual property.
Agents and Representatives of Company
The Company shall inform its agents, consultants, independent
contractors and representatives
of their responsibility to act, on behalf of the Company, consistent with this Policy, other
Company statements and policies and any applicable law or
regulation. Compliance shall be
monitored.
Use of Technology
The Company's electronic communication resources (voicemail, email, facsimile, internet,
computers, etc.) should be used properly and reasonably, making sure that the equipment and
8
the information it contains remain secure. Personal use of these
resources is permitted if
reasonable and appropriate. Personal information transmitted, using or stored on the
Company's systems, will not be regarded as private and confidential
and the Company reserves
the right to access, without notice, any such use. Personnel should be aware that e-mails to
external parties have the same effect in law as other forms of written communication and must
not send e-mails or other electronic communication making
representations or commitments
on behalf of the Company unless authorised to do so. Company IT
policies, including the use of
passwords, anti-virus software and regular back-ups, must be complied with by all Personnel at
all times.
Company Communications and Disclosures
These are messages and statements from the Company to third
parties about the Company and
its business. Where these are made to shareholders or are made
public they will form the basis
on which third parties may decide whether to buy, sell or retain shares in the Company. Any
message and statement issued by or on behalf of the Company should be timely, accurate,
complete, truthful and reliable and comply with any applicable
securities regulations and laws.
None should be issued with appropriate internal approval, up to and
including the Board.
Personnel should also take particular care about what they say
concerning the Company at
meetings and other public events.
Delegation of Authority
All employees, officers and directors share in the overall responsibility for the sound
management of the Company's finances and resources and each has a responsibility to be
aware of and to comply with relevant Company policies, control procedures and operating
systems.
Any Personnel or other persons acting on behalf of the Company who develop a contract or
recommend that the Company enter into a contract shall take all
reasonable steps to ensure
the sound management of the Company's interests and resources. The Company expects all
those who may be involved in the contracting process on behalf of the Company to act ethically
and diligently in carrying out their responsibilities to the Company.
No person may enter into arrangements purporting to bind the
Company to contractual or
other obligations unless he or she has expressly been granted
authority to do so.
If any Personnel become aware of any circumstances suggesting non­compliance, irregularity or
impropriety relating to the matters addressed in this section, they
should promptly notify the
Managing Director, who will investigate and take appropriate action to ensure accountability
for the sound day-to-day management of the funds and resources of
the Company.
9
Gifts, Hospitality and Entertainment
The Company only offers, promises, gives, requests or receives gifts, entertainment or
hospitality for business (or allows Personnel to do the same) if these
are reasonable. Under no
circumstances may the gifts, entertainment or hospitality be offered,
promised, given,
requested or accepted if they could influence a business decision
improperly or if they are
material or frequent.
Personnel must not use their status or position with the Company to
obtain personal gain from
those doing or seeking to do business with the Company. Except as
provided herein, Personnel
must neither seek nor accept gifts, entertainment, hospitality or any
other benefit from any
person or from any organisation or group that does (or is seeking to
do) business with the
Company, or from a competitor of the Company or any of its affiliates, that may compromise
(or may be seen to compromise) their judgement.
Personnel may offer, promise, give or accept reasonable gifts,
entertainment and hospitality
provided this is not reasonably likely to cause personal embarrassment to the individual or to
the Company or could be seen as possibly compromising that
individual's ability to act
independently in the best interests of the Company.
If an employee, officer or director of the Company is offered a gift,
entertainment or hospitality that is disproportionate and that is likely to be seen as compromising their judgement, or is
offered any payment then the offer should be promptly (and politely) rejected in writing by
explaining that the Company's Code of Ethics prohibits the individual from accepting the offer.
That communication must be copied to the Managing Director and any gift received returned to
the sender.
If it is not feasible to refuse or return a gift, whether because it is not practical or possible to do
so, or because to do so may cause offence, the Personnel in question must notify the Managing
Director requesting instructions. The Managing Director shall then consider the gift and direct
how it should be treated, which may include returning it to the person who gave it, donating it
to charity or surrendering it to the appropriate authorities.
Personnel must at no time permit themselves to be influenced or to act improperly during the
course of their employment, appointment or duty to the Company as a result of any gift
offered, promised or given to them. Failure to do this may result in Personnel committing an
offence under applicable anti-bribery laws.
Whatever the circumstances, all gifts exceeding £100 in value (or assumed value), or its
equivalent in any other currency, must be declared before being accepted or given (or, if this is
not possible, as soon as possible thereafter) to the Managing Director. However, the fact that a
gift does not exceed this value (or assumed value) does not relieve Personnel of their duty to
report any disproportionate gift, expenditure or hospitality in accordance with this Policy and
does not mean that such a gift cannot constitute a Bribe.
Those Personnel whose duties require them to do so may offer, promise or give modest gifts,
entertainment or hospitality if all of the following tests are met:
10 • the gift, entertainment or hospitality is not cash, a gift certificate or other negotiable
instrument;
• the gift or other benefit cannot reasonably be interpreted as an improper payment or
inducement;
• the gift, entertainment or hospitality does not contravene any applicable law and, in
addition, is made in accordance with generally-accepted local ethical practices (noting
that the fact that such a gift, entertainment or hospitality is customary in the local
territory does not mean that it is lawful under applicable law);
• the entertainment or hospitality occurs infrequently;
• the entertainment or hospitality arises during the Company's ordinary course of
business;
• the entertainment or hospitality involves reasonable and not lavish expenditure -the
amounts involved should be amounts the individual is accustomed to spending on his or
her own business and personal entertainment (and not amounts which might be likely
to influence him or her) and which, if subsequently disclosed to the
public, would not in
any way embarrass the Company or the recipient,
• the gift, entertainment or hospitality has the prior written approval of the Managing
Director;
• the gift, entertainment or hospitality is publicly and openly given and not provided in
circumstances of secrecy or concealment; and
• the recipient is asked to report the gift, entertainment or hospitality to their employer
or principal.
Any Personnel in doubt regarding the proper course of action should promptly refer the matter
to the Managing Director.
.ANTI-BRIBERY AND CORRUPTION
The Company and Personnel must not offer, promise, give, request or accept or agree to accept
any Bribe in any form, whether directly or indirectly. The Company and Personnel must not
participate in or tolerate any Corruption, whether directly or through
any third party. The
Company and Personnel must not give, receive, ask for or permit
anyone else, to give Bribes or
enter into Corruption to win new business, retain existing business or further the Company's
interests. In particular:all dealings between Personnel and Public Officials must be
conducted in a manner that
will not compromise the integrity or impugn the reputation of any Public Official or
11Personnel. Non-routine and high profile contacts with Public Officials must be handled
by or coordinated by the Managing Director; • the Company and Personnel must not make Facilitation Payments in any country or
allow any person to make Facilitation Payments on behalf of the
Company or any
Personnel;
• the Company and Personnel should not pay more than a fair market price for goods and
services;
• the Company and Personnel must not hide or fail to record properly activities or falsify any Company records or accounts
• the Company and Personnel must check that fees paid by the Company for services
from third parties, including agents, advisors and consultants, are for legitimate
business purposes and are consistent with the service provided;
• Personnel must understand and follow all the applicable Bribery and Corruption laws
that apply in the countries in which the Company does business and may contact the
Managing Director for advice on which laws apply and what restrictions they impose;
• Personnel must report any attempts to Bribe them or the Company or to request Bribes
from them or the Company and any suspicions of Corruption in the business of the
Company to the Managing Director.
It is recognised that there are circumstances in which Personnel are left with no alternative but
to make a Facilitation Payment or other payment in order to protect against loss of life, limb or
liberty. Under some laws, that Personnel may have a legal defence against a prosecution for
Corruption or Bribery, such as the defence of duress. However, laws across other territories
operate differently and this defence is not always available. Where it is feasible to do so,
Personnel should contact the Managing Director, who will endeavour to assist Personnel and
discuss any options available.
The following are examples of potential Bribes or corrupt activity:
• making or offering a payment in order to influence a decision to award a contract to the
Company;
• making or offering a payment in order to influence the timing of the issue of any official
authorisation or documentation, including any certificate, approval, permit or licence;
and
• making or offering a payment in order to relieve the Company of any governmental or
statutory obligations, such as paying taxes, passing inspections or obtaining government
authorisations.
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Personnel who commit or collude in any Corruption or offering, promising, giving, requesting or
accepting any Bribe may incur criminal liability on themselves and
(potentially) the Company as
well.
Bribery Risk Assessment
The Company will regularly assess its exposures to potential external and internal risks of
Bribery on its behalf by Associated Persons. The risk assessment will be overseen by the
Managing Director and will be carried out using internal information,
such as responses to
questionnaires and comments from training sessions for this Code and Policy, and external
information sources, such as UK Government advice and reputable
non-governmental
organisations like Transparency International. The assessments will
review country, sector,
transaction, business opportunity and business partnership risk in the Company's operations.
The risk assessment will also review how the Company's internal
structure and procedures
affect the Bribery risk, including Personnel training and knowledge of this Code and Policy.
Due Diligence of Associated Persons.
The Company will carry out thorough due diligence on Associated
Persons to satisfy the
Company that the Associated Persons are not likely (whether directly or indirectly) to Bribe or
engage in Corruption and will review and periodically repeat similar
due diligence on existing
Associated Persons. The Due Diligence carried out should reflect the requirements of the risk
assessment, and it may be appropriate to include direct face-to-face enquiries of the Associated
Persons, inspection of offices and verification of resources, checks on publically available
resources, use of risk-control agents and investigators, requesting CVs and resumes and
following up references.
Business Relationships with Associated Persons
It is the responsibility of all Personnel whose work involves them
dealing with Associated
Persons, to monitor the behaviour of those Associated Persons for
conduct that may
contravene the requirements of this Code and Policy and any
applicable law. Any concerns
must be promptly reported by Personnel to their immediate supervisor or the Managing
Director. Future agreements with Associated Persons outside the
Company's organisation
should, where at all possible, require that the Associated Person
complies with Anti-Bribery and
Corruption policies equivalent to the relevant provisions of this Code
and Policy.
In particular, no Personnel may make any payment or provide any
other advantage to an
Associated Person if they believe that that Associated Person will or might use that payment or
other advantage as a Bribe or for the purpose of Corruption. If
Personnel suspect that any
Associated Person intends to do so (whether or not any payment or
advantage has been provided), they must immediately inform the Managing Director.

Training and Communication
Regular face-to-face training on this Code and Policy will be provided to Personnel. The training
will also seek to raise the awareness of Personnel about Bribery and Corruption in the business
13
and countries in which the Company operates and the ways the
Company addresses these,
including the Risk Assessment and its results.
Personnel will also be required to sign certificates of compliance with this Code and Policy in
the form of Appendix A on starting work with the Company and at the end of each calendar
year in the form in Appendix B.
Any concerns about Bribery or Corruption in the Company's business on the part of Personnel
or Associated Persons can be raised confidentially with the Managing Director.
Monitoring and Review
The Managing Director is responsible for evaluating the effectiveness of this Code and Policy
and for reviewing and (if appropriate) proposing amendments to this Code and Policy in light of
changes in applicable law, governmental changes in the countries in which the Company
operates, any incidents of Bribery or Corruption of which the Company becomes aware, and
press reports. The Managing Director will if appropriate, get external verification of the
effectiveness of the anti-Bribery and Corruption provisions of this Code and Policy.
Enforcement
In the case of employees, breach of this Code and Policy will be dealt with under the Company's
Disciplinary Procedure. Serious breaches, in particular any breach of the Anti-Bribery and
Corruption provisions, may result in summary dismissal. In the case of contractors, agents,
intermediaries, representatives, advisers, suppliers, joint-venture
partners and other
contractual counterparties, breach of this Code and Policy may result in immediate termination
of their contract.

Bribery Risk Assessment
The Company will regularly assess its exposures to potential external and internal risks of
Bribery on its behalf by Associated Persons. The risk assessment will be overseen by the
Managing Director and will be carried out using internal information, such as responses to
questionnaires and comments from training sessions for this Code and Policy, and external
information sources, such as UK Government advice and reputable non-governmental
organisations like Transparency International. The assessments will review country, sector,
transaction, business opportunity and business partnership risk in the Company's operations.
The risk assessment will also review how the Company's internal structure and procedures
affect the Bribery risk, including Personnel training and knowledge of this Code and Policy.
Due Diligence of Associated Persons.
The Company will carry out thorough due diligence on Associated Persons to satisfy the
Company that the Associated Persons are not likely (whether directly or indirectly) to Bribe or
engage in Corruption and will review and periodically repeat similar due diligence on existing
Associated Persons. The Due Diligence carried out should reflect the requirements of the risk
assessment, and it may be appropriate to include direct face-to-face enquiries of the Associated
Persons, inspection of offices and verification of resources, checks on publically available
resources, use of risk-control agents and investigators, requesting CVs and resumes and
following up references.
Business Relationships with Associated Persons
It is the responsibility of all Personnel whose work involves them dealing with Associated
Persons, to monitor the behaviour of those Associated Persons for conduct that may
contravene the requirements of this Code and Policy and any applicable law. Any concerns
must be promptly reported by Personnel to their immediate supervisor or the Managing
Director. Future agreements with Associated Persons outside the Company's organisation
should, where at all possible, require that the Associated Person complies with Anti-Bribery and
Corruption policies equivalent to the relevant provisions of this Code and Policy.
In particular, no Personnel may make any payment or provide any other advantage to an
Associated Person if they believe that that Associated Person will or might use that payment or
other advantage as a Bribe or for the purpose of Corruption. If Personnel suspect that any
Associated Person intends to do so (whether or not any payment or advantage has been
provided), they must immediately inform the Managing Director.