Anti-Bribery Policy

In relation to the transactions, neither Consultant or Vendor nor any of its Related Parties has made, offered or authorized or will make, offer or authorize any payment, gift, promise or other advantage, whether directly or through any other person or entity, to or for the use or benefit of any Officials or any entity or other person where such payment, gift, promise or other advantage would (i) comprise a Facilitation Payment; or (ii) violate the Anti-Bribery and Money-Laundering Laws and Obligations or any other applicable Law.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. We neither make bribes nor accept them, nor induce or permit any other party to make or receive bribes on our behalf. You shall not offer or accept gifts, hospitality or other inducements which influence a decision, or engage in any form of bribery. Entertainment of our personnel or clients that is lavish or inappropriate is also not permitted. In addition, you have an obligation to comply with our code of conduct policy.