Cementors

1. Purpose and Scope

This Anti-Corruption and Business Ethics Compliance Policy ("Policy") establishes the standards and expectations for ethical business conduct and compliance with anti-corruption laws applicable to Cementors Limited ("Company"). This Policy applies to all employees, directors, officers, contractors, and third parties acting on behalf of the Company in the United Kingdom and internationally.

2. Anti-Corruption Compliance

The Company is committed to conducting business with integrity and in compliance with the UK Bribery Act 2010 and other applicable anti-corruption laws. It is strictly prohibited for any employee or representative of the Company to:

Offer, give, request, or receive a bribe in any form, whether directly or indirectly.

Engage in any facilitation payments, unless facing a credible and immediate threat to safety.

Provide anything of value to influence or improperly benefit from a business decision.

Fail to properly record and report transactions in Company records.

3. Business Ethics

The Company upholds the highest ethical standards and expects employees to:

Conduct business honestly and transparently.

Avoid conflicts of interest and disclose any potential conflicts.

Act in the best interests of the Company and its clients.

Comply with all applicable laws and regulations governing our business activities.

4. Payment of Commissions and Fees

All commissions, fees, and other payments must be lawful, reasonable, and documented.

The Company prohibits excessive or undisclosed commission payments that could be considered bribes.

Any commission payments must be pre-approved by senior management and supported by appropriate documentation.

5. Gifts, Hospitality, and Entertainment

Employees may provide or accept modest gifts and entertainment in line with customary business practices, provided they are not intended to improperly influence a business decision.

Any gifts or entertainment must be reasonable in value, infrequent, and transparently recorded.

Gifts, hospitality, or entertainment offered to government officials require prior approval from the Compliance Officer and must comply with applicable laws.

Cash or cash-equivalent gifts are strictly prohibited.

6. Dealings with Government Officials

Special care must be taken when dealing with government officials.

The Company prohibits any payments, gifts, or favors intended to gain an unfair business advantage.

Employees must not make charitable contributions or donations on behalf of the Company in exchange for business benefits.

7. Third-Party Due Diligence

The Company conducts due diligence on all third-party intermediaries, including agents, consultants, and contractors, to ensure they comply with anti-corruption laws.

All contracts with third parties must include anti-corruption compliance clauses.

Employees must report any red flags related to third-party conduct.

8. Record-Keeping and Financial Controls

Accurate financial records must be maintained to reflect all transactions transparently.

Employees must not falsify records or misrepresent financial information.

Any expenses related to gifts, hospitality, or payments must be properly documented and approved.

9. Reporting Violations

Employees must report any suspected violations of this Policy to the Compliance Officer.

Reports can be made confidentially and without fear of retaliation.

The Company will investigate all reports promptly and take appropriate corrective action.

10. Consequences of Non-Compliance

Violations of this Policy may result in disciplinary action, including termination of employment and legal consequences.

The Company reserves the right to report any criminal activities to relevant authorities.

11. Training and Awareness

Employees must complete periodic training on anti-corruption laws and business ethics.

The Company will provide resources and guidance to support compliance efforts.

12. Policy Review and Updates

This Policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, and best practices.

For any questions or concerns regarding this Policy, please contact the Compliance Officer at [email protected].