1st August 2014

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,


Mr. Amit Parekh
Procurement Director

2. HUMAN RIGHTS
2.1 The Company 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 The Company 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 The Company 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 and concerns through the listed individuals with special responsibility and oversight in this area.

Gapuma UK Ltd was successfully accredited as compliant with ISO 9001:2008 Management System in 2013 and the adoption of this standard has helped to provide a framework for monitoring and evaluating the performance of all employees, suppliers and other trading partners in regard to our core values.

Specifically, the implementation of an 'Opportunities for Improvement' Log allows for employees to report or highlight any areas of concern for internal audit and subsequent analysis at a Quarterly Management Review meeting. This QMR is attended by the Managing Director and internal auditors. All log entries, internal audits, QMR and other meetings and any subsequent remedial actions are reviewed annually during an external audit carried out by UKAS accredited ISO Auditors DNV Certification Ltd.

3. WORKERS’ RIGHTS
3.1 The Company is committed to complying with all relevant employment
legislation and regulations. The Company 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 / paternity leave and such other leave as is granted by
legislation as a minimum.
3.4 The Company 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 and concerns through the listed individuals with special responsibility and oversight in this area.

Gapuma UK Ltd was successfully accredited as compliant with ISO 9001:2008 Management System in 2013 and the adoption of this standard has helped to provide a framework for monitoring and evaluating the performance of all employees, suppliers and other trading partners in regard to our core values.

Specifically, the implementation of an 'Opportunities for Improvement' Log allows for employees to report or highlight any areas of concern for internal audit and subsequent analysis at a Quarterly Management Review meeting. This QMR is attended by the Managing Director and internal auditors. All log entries, internal audits, QMR and other meetings and any subsequent remedial actions are reviewed annually during an external audit carried out by UKAS accredited ISO Auditors DNV Certification Ltd.

Gapuma (UK) Limited recognises that it has a responsibility to the environment beyond legal
and regulatory requirements. We are committed to reducing our environmental impact and
continually improving our environmental performance as an integral part of our business
strategy and operating methods, with regular review points. We will encourage customers,
suppliers and other stakeholders to do the same.

2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.
8. 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.
9. 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 CO2 and help the
community.

Gapuma UK Ltd was successfully accredited as compliant with ISO 9001:2008 Management System in 2013 and the adoption of this standard has helped to provide a framework for monitoring and evaluating the performance of all employees, suppliers and other trading partners in regard to our core values.

Specifically, the implementation of an 'Opportunities for Improvement' Log allows for employees to report or highlight any areas of concern for internal audit and subsequent analysis at a Quarterly Management Review meeting. This QMR is attended by the Managing Director and internal auditors. All log entries, internal audits, QMR and other meetings and any subsequent remedial actions are reviewed annually during an external audit carried out by UKAS accredited ISO Auditors DNV Certification Ltd.

Additionally, as part of our ISO framework we set the following Quality Objective: To reduce all paperwork generated in the London office by 20%. To be measured by cost spent on copy paper per annum. Target January 2014

We were successful in meeting this target.

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.

3. DEFINITIONS
For the purposes of this Code and Policy the following definitions apply:
Associated Person means any Personnel or other person performing services for or on behalf of
the Company.
Bribe means any financial or other advantage, including facilitation payments, cash gifts,
hospitality or kickbacks, entertainment, designed to induce someone to act improperly or to
reward someone for doing so.
Corruption means any act of bribery, extortion, fraud, deception, collusion, participation in an
abuse of power, or money laundering.
Facilitation Payments means sums of money paid to a Public Official (or other persons) as a
way of ensuring that they perform their duty, either more promptly or at all.
Public Official means an individual who:
(a) holds a legislative, administrative or judicial position of any kind, whether appointed or
elected, of a country or territory (or any subdivision of a country or territory);
(b) exercises a public function:
(i) for and on behalf of a country or territory (or any subdivision of such a country
or territory); or
(ii) for any public agency or public enterprise of that country or territory (or
subdivision);
(c) is an official or agent of a public international organisation being an organisation whose
members are:
(i) countries or territories
(ii) government of countries or territories;
(iii) other public organisations; or
(iv) a mixture of any of the above; or
(d) is a candidate for public office or a member of the governing body or similar of any
political party.
Personnel means directors, officers, employees, consultants and contractors employed by or
contracting with the Company, acting on the Company's business.

4. 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.

6. 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:
o arises 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;
6
• 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.
7. BUSINESS CONDUCT
Fraud, Deception and Dishonesty
The Company and its Personnel must not defraud anyone or act dishonestly. 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
threatened.
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

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

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 non-compliance, 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.

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:
• 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.
8. 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

Personnel. 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.

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 résumés 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

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.
9. SANCTIONS AND ANTI-MONEY LAUNDERING PROCEDURES
The Company must complete certain procedures before it can transact with or for any new
client or counterparty.
Before transacting with or for any person, Personnel must check that person’s current status on
the Client Database or with the Managing Director. If the name is not on the list, Personnel
must immediately pass details to the Managing Director and not deal with that person until
the Managing Director authorises you them to do so.
If Personnel have any doubt as to whether they can trade with a particular client or
counterparty on behalf of the Company, they must consult the Managing Director before doing
so.
The Company must complete due diligence on any new client or counterparty. Personnel must
cooperate with any requests for information and not start business before the process is
complete.

What are sanctions?
Sanctions are a tool used by the international community for several purposes. They could be
used:
• to encourage a change to the practices of a country or regime
• to pressurise countries or regimes into compliance with standards
• like an enforcement tool if other diplomatic means fail and international peace and
security are threatened
• to prevent and suppress terrorist financing and activity
Sanctions can take various forms but typically:
• prohibit inwards funds transfer
• freeze current and prohibit future dealings with named individuals or entities, be they
countries or institutions
Sanctions restrictions apply to everyone in the UK, regardless of their business.
Breach of sanctions restrictions is a criminal offence. The Company takes compliance with
the sanctions regime seriously.
The UK sanctions regime
The UK has sanctions regimes to enforce trade and financial sanctions. Its regimes take account
of resolutions of the United Nations and the European Union as well as UK domestic measures.
The regimes are run by the Department for Business, Innovation and Skills (BIS) for Trade
Sanctions and HM Treasury for financial sanctions.
The UK financial sanctions regime lists individuals and entities that are subject to financial
sanctions. These individuals and entities can be in the UK, elsewhere in the EU or the rest of
the world.
The Treasury keeps the list of sanctioned parties in the UK (the HMT list). The list includes both
UK and overseas individuals and entities.
The HMT list stems from financial sanctions orders. Each financial sanctions order comes from
a statutory instrument and/or EC Regulation. The relevant legislation will specify the services a
firm may or may not provide to the named individuals and/or entities.
In general terms, without a licence from HMT firms may not provide funds to those on the HMT
list. A firm must tell HMT's Asset Freezing Unit as soon as practicable where it has identified an
actual match with a person or entity on the HMT list, or where it knows or suspects that a
customer or a person with whom the firm has had business dealings has dealt with sanctioned
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persons. A firm must also supply any information that would help compliance.
A failure to comply with these obligations can carry serious consequences. For example, it
carries the risk of the government seeking criminal penalties against the firm and, in certain
circumstances, against the firm's management. A breach of the regime may also result in
reputational damage to firms.
Who must comply with financial sanctions in place in the UK?
The safest principle is to assume the financial sanctions regime applies to everyone, not only
those who carry on business in certain sectors.
The relevant UK statutory instruments apply to:
• any person in the UK;
• any person elsewhere who is a British citizen, a British Overseas territories citizen, a
British Overseas citizen, a British subject, a British National (Overseas), or a British
protected person; and
• any body incorporated or constituted under the law of any part of the UK or a Scottish
partnership, including banks, financial institutions, charitable organisations and nongovernmental
organisations, in the UK or established under UK law.
The UK statutory instruments do not apply to subsidiaries operating wholly outside the UK
which do not have legal personality under UK law.
EC Regulations imposing and/or implementing sanctions are part of Community law, are
directly applicable and have direct effect in the Member States. The measures apply to:
• nationals of Member States;
• entities incorporated or constituted under the law of one of the Member States; and
• all persons and entities doing business in the EU, including nationals of non-EU
countries.
UK statutory instruments enable Treasury to impose penalties for a breach of a Regulation.
Trade sanctions
In addition to financial sanctions, certain international trade sanctions prevent dealing with
entities in specific jurisdictions where to do so would potentially finance certain activities.
When transacting with a new client or counterparty, the Managing Director will screen its
activities against trade sanctions lists and may need further information before approving deals
involving sanctioned jurisdictions.

Orders under Counter Terrorism Legislation
Separately, Treasury has the power to make orders under the Counter-Terrorism Act 2008.
These Orders have a similar effect to those made under sanctions legislation, in restricting or
banning dealings with entities or individuals listed.
US sanctions
The US sanctions regime, administered by the US Office of Foreign Assets Control (OFAC), is
very wide and has in the past brought trouble to UK businesses. Although the Company has no
physical presence in the US, in principle, if any business with any client or counterparty
involves:
• a person that is a US listed or incorporated entity or has activities;
• business conducted in US Dollars or through a US intermediary;
• a US national employed by the Company
you must discuss this in advance with the Managing Director.
Sanctions policy
• The Managing Director will screen any person with or for whom the Company will
transact against the HMT list and against Export Control Organisation warnings at take
on of business. Screening includes not only the corporate name of those the Company
deals with but also the directors and beneficial owners of corporate clients.
• Treasury updates its lists periodically, often several times a month. Each time the list
updates, the Managing Director will screen the Company’s client list against the
changes.
• The Managing Director will also regularly run the entire client database through an up to
date consolidated HMT list.
• It is important that the Managing Director knows of any words or names that are likely
to be relevant when assessing any potential sanctions issues. For example, if a
Customer is sometimes known by another name, or uses alternative spellings.
Treatment of potential target matches
A match found during screening does not necessarily mean the firm is dealing with an actual
target on the HMT list. If the Company finds an actual target match or freezes an account
because of suspicion that an individual or entity is acting on behalf of a listed individual or
entity, we must report the matter, as soon as reasonably practicable, to HMT’s Asset Freezing
Unit (AFU).
If a match is found, the Managing Director will report to HMT as soon as reasonably practicable
(or decide that a potential target match is a false positive and to document this). When a
match is found, no person should do business with the reported entity or individual without the
express permission of the Managing Director. The Managing Director will deal with HMT and
any necessary licence applications.
Most listed individuals and entities are aware that they are on the HMT list, which is publicly
available. The financial sanctions regime is legally distinct from the anti-money laundering
regime.
Anti-Money Laundering
The Company must separately be alert to the possibility of being used as an unwitting conduit
for criminal moneys. If any employee has any reason to suspect funds received by the company
are the proceeds of activity that would be a criminal offence if it took place in the UK, they
must report immediately to the Managing Director. The Managing Director will, if appropriate,
report the suspicion to the Serious Organised Crimes Agency. Where there is any reason for
suspicion, this must not be disclosed to the suspect or to any other person without express
consent of the Managing Director.
10. IDENTIFICATION AND REPORTING PROCEDURES
If Personnel become aware of a violation or possible violation of this Policy, they must report
that information immediately to the Managing Director. The violation or possible violation may
be reported on an anonymous basis.
Personnel must also report questionable financial reporting, accounting, internal control or
auditing matters in writing to the Managing Director. The questionable practice may be
reported on an anonymous basis.
The Company will not permit any form of retaliation (including dismissal) against anyone who
has truthfully and in good faith reported any violation or possible violation of this Policy unless
the individual reporting is one of the violators.
All Personnel must cooperate fully in any investigation conducted on behalf of the Company
relating to possible violations of this policy.
The Company will, where possible and lawful, keep the reporter’s identity unknown, defend the
reporter in any legal action arising out of or in connection with his or her report or provision of
information and take all reasonable steps to protect the reporter and ensure he or she does not
lose out financially.
11. CONDITION OF APPOINTMENT OR EMPLOYMENT
It is a condition of appointment and/or employment (as applicable) that Personnel at all times
abide by the standards, requirements and procedures set out in this Policy. On appointment

Personnel will be required to complete a certificate of compliance as set out in Appendix A
declaring that they have read and understood this policy and that they agree to comply with
the provisions of this Policy. On an annual basis, Personnel will be required to complete an
annual statement of compliance as set out in Appendix B.
Any departure from any of the standards, requirements and procedures set out in this Policy is
prohibited and the Company may take such steps or proceedings in respect of any violation or
non-compliance as may be available to it, including, but not limited to, disciplinary action up to
and including the removal from office or the termination of employment or relationship with
the Company.

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
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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.

Gapuma UK Ltd was successfully accredited as compliant with ISO 9001:2008 Management System in 2013 and the adoption of this standard has helped to provide a framework for monitoring and evaluating the performance of all employees, suppliers and other trading partners in regard to our core values.

Specifically, the implementation of an 'Opportunities for Improvement' Log allows for employees to report or highlight any areas of concern for internal audit and subsequent analysis at a Quarterly Management Review meeting. This QMR is attended by the Managing Director and internal auditors. All log entries, internal audits, QMR and other meetings and any subsequent remedial actions are reviewed annually during an external audit carried out by UKAS accredited ISO Auditors DNV Certification Ltd.