Ethics and Compliance

SECTION 16. SCHEDULE 1 – STATEMENT OF ETHICS

1. The Sepro Group operates in many jurisdictions around the world. We pride ourselves on our reputation for acting fairly and ethically. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity.

2. You have been provided with this statement of ethics because you are an individual employed or associated with the Sepro Group.

3. The Sepro Group condemns corruption in all its forms and will not tolerate it in our business or in those we do business with.

5. Our Anti-Corruption Policy sets out in detail how you should behave and what you should do if you are confronted with corruption.

6. The Anti-Corruption Policy is for your benefit as much as for Sepro Group’s. If convicted of a bribery offence, any member of the Sepro Group might get a significant fine and suffer lasting reputational damage. If you are convicted of a bribery offence, you could face up to ten years in prison. The potential harm done by bribery is long term and hugely outweighs any potential short term gain. Bribery is just not worth the risk.

7. If you have any doubts about anything at all relating to corruption, refer to the Anti-Corruption Policy or speak to your compliance officer. The management of the Sepro Group will stand by you in acting ethically.

8. Remember, take the RIGHT approach, and we can eradicate corruption together:

8.1 Responsibility. You are responsible for your actions. If you break the law, you will have to face the consequences – which could mean a fine, imprisonment, or both.

8.2 Integrity. Don’t compromise your integrity. If you think something is wrong, ALWAYS report it. If you aren’t sure, consult the Anti-Corruption Policy. Don’t ever let yourself be forced into doing something you know or suspect is wrong.

8.3 Genuineness. Always pay genuine prices for genuine goods and services.. Agents who ask for especially large fees or commissions may do so in order to pay bribes on your behalf. If this happens, you will be responsible.

8.4 Honesty. Act honestly and in good faith at all times and in all aspects of your work.

8.5 Transparency. Keep accurate records (including all invoices and receipts) of everything that you do. Full and accurate records demonstrate complete transparency and that you have nothing to hide.

9. Don’t bribe. Do the RIGHT thing.