Nine Tracks Limited Anti-Corruption and Bribery Policy

Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-corruption and bribery regulations and to ensure that Nine Tracks Limited conducts its business in a socially responsible manner.

Policy Statement

Nine Tracks Limited is committed to conducting all of its business in an honest and ethical manner. 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. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.

Scope

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).

Definitions

• Bribery: Offering, promising, giving, accepting, or soliciting an advantage as an inducement for action which is illegal or a breach of trust.
• Corruption: Abuse of entrusted power for private gain.
  

Prohibited Conduct

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not:

• Offer, give, or receive any gift or hospitality that could be regarded as illegal or improper, or which violates the recipient’s policies.
• Offer, give, or receive any gift or hospitality to any public employee or government officials or representatives, or politicians or political parties.
• Make facilitation payments to expedite or secure the performance of a routine governmental action.

Gifts and Hospitality

Gifts and hospitality are acceptable provided they:

• Are not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.
• Comply with local law.
• Are given in the name of the company, not in an individual’s name.
• Do not include cash or a cash equivalent (such as gift certificates or vouchers).
• Are appropriate in the circumstances (e.g., small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
• Are of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
• Are given openly, not secretly.

Political Contributions

Nine Tracks Limited does not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates.

Charitable Contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in-kind services, knowledge, time, or direct financial contributions. However, employees must ensure that charitable contributions are not used as a scheme to conceal bribery.

Record-Keeping

Nine Tracks Limited will keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

Responsibilities

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for Nine Tracks Limited or under its control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Reporting

Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your manager or the compliance officer.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Nine Tracks Limited reserves the right to terminate its contractual relationship with other workers if they breach this policy.