Anti-Corruption and Bribery Policy Statement

The Hockley International Group is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on Hockley International Group's behalf is responsible for conducting company business honestly and professionally.

The Hockley International Group considers that bribery and corruption has a detrimental impact on business by undermining good governance and distorting free markets. The Hockley International Group benefits from carrying out business in a transparent and ethical way and by helping to ensure that there is honest, open and fair competition in our sectors. Where there is a level playing field, The Hockley International Group can lead the market through innovation and by delivering excellent services and products to its customers.

The Hockley International Group does not tolerate any form of bribery by, or of, its employees or any persons or companies acting for it or on its behalf. The Board and senior management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, in accordance with the United Kingdom Bribery Act 2010. The Hockley International Group has issued an ethical behaviour policy outlining The Hockley International Group's policy on preventing and prohibiting bribery. The ethical behaviour policy applies to all employees and they are required to familiarise themselves and comply with this policy.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of The Hockley International Group are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its anti‐bribery measures, The Hockley International Group is committed to engage only in transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure.

A breach of The Hockley International Group's ethical behaviour policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal. Employees and other individuals acting for The Hockley International Group should note that bribery is a criminal offence that may result in up to 10 years' imprisonment and/or an unlimited fine for the individual and an unlimited fine for The Hockley International Group.

The Hockley International Group will not conduct business with service providers, agents or representatives that do not support The Hockley International Group's anti‐bribery objectives.

The success of The Hockley International Group's anti‐bribery measures depends on everyone playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, The Hockley International Group are encouraged to report any suspicious activity to the Compliance Officer (Central Services Manager). The Hockley International Group’s Executive Board will support any individuals who make such a report in good faith.