Sample Anti-Corruption Policy

V4.01 January 2019

The Company agrees to adopt an “Anti-Corruption Policy” as follows:

1. The Company should adopt policies and procedures that are reasonably designed to enable the company, its affiliated companies and its owners, directors, managers, officers and employees and agents to comply with all applicable anti-corruption laws and regulations for all jurisdictions in which the company does business including, without limitation, the U.S. Foreign Corrupt Practices Act, the UN Convention Against Corruption and the OECD Convention (collectively “Anti-corruption Laws”).

2. The Company should establish and maintain proper books, records and accounts which, in reasonable detail, accurately and fairly reflect the transactions of the Company and the Company’s assets.

3. The Company should establish and maintain a proper set of internal controls sufficient to provide reasonable assurances that transactions are executed and access to bank accounts is permitted only in accordance with the Company’s applicable policies and procedures and management’s authorization;

4. The Company must use only ethical, legitimate and legal business practices in the operation of its business and in promoting the company’s interests before government authorities.

5. Company personnel, representatives, agents, consultants and intermediaries may not:

(a) make any payment or transfer of value with the intent, purpose or effect of engaging in commercial bribery;

(b) facilitate or agree to kickbacks or other unlawful or improper means of obtaining or retaining business; or

(c) promise, offer or give to a government official, directly or indirectly, any money or anything else of value, to or for the benefit of the government official himself or herself or another person or entity, in order to induce or influence the government official to act or refrain from acting in the exercise of his or her official duties in relation to the business of the Company.