Anti-Bribery, Gifts and Intermediaries

1 Purpose

The purpose of this Policy is to ensure that business is won and conducted on merit, transparent commercial terms and lawful relationships. Bribery, facilitation payments, kickbacks and concealed benefits are prohibited regardless of local custom, commercial pressure or perceived benefit to DE Trading.

2 Scope

This Policy applies to directors, employees, consultants and anyone acting for DE Trading. It also sets expectations for brokers, introducers, agents, advisers, joint-venture partners, logistics providers and other intermediaries.

The stricter of applicable law, this Policy or a binding contractual requirement should be followed. Where uncertainty exists, the transaction or benefit must be paused and escalated.

3 Prohibited conduct

• Offering, promising, giving, requesting or accepting anything of value to influence a decision improperly.
• Making a facilitation or grease payment, except where an immediate threat to health or safety leaves no safe alternative; any such event must be reported and recorded promptly.
• Using a third party, inflated commission, false invoice, rebate, donation, employment offer or other arrangement to conceal an improper benefit.
• Making cash gifts or cash-equivalent gifts, secret commissions, kickbacks or payments to an unrelated bank account without documented lawful grounds and approval.
• Retaliating against a person who refuses an improper payment or raises a concern in good faith.

4 Gifts hospitality public officials and political activity

Gifts and hospitality must be modest, infrequent, lawful, transparent, connected to a legitimate business purpose and unlikely to influence or appear to influence a decision. They must never be offered during a live tender or approval process where this could create an improper advantage.

Benefits involving a public official require particular care and prior written Director approval. Political contributions or support in DE Trading's name require prior written approval by the Directors, a documented lawful purpose and legal review where appropriate. Personal political activity must not use company funds, branding or authority.

• A separate approval schedule may set monetary limits by jurisdiction; until approved, any non-routine benefit should be disclosed in advance.
• Gifts and hospitality offered, received or declined above the approved reporting level should be entered in a register.
• Charitable support must be subject to proportionate due diligence and may not be used to route a benefit to a decision-maker.

5 Intermediaries and commissions

An intermediary must be engaged only for a clear, necessary and lawful service. Before appointment, DE Trading should verify identity, ownership, experience, relationships, reputation, sanctions status and the commercial reason for the engagement.

The written agreement should define services, territory, term, fee basis, compliance obligations, audit or information rights where proportionate, and termination rights. Fees must be commercially reasonable, supported by evidence of work and paid to an account in the contracted party's name in an appropriate jurisdiction.

• Red flags include requests for secrecy, unusually high or success-only fees, vague services, public-official connections, offshore or third-party payment, false invoices and resistance to due diligence.
• No intermediary may be used to do anything that DE Trading could not lawfully do itself.
• Material exceptions require documented Director approval and legal advice where appropriate.

6 Roles approval and reporting

The Directors are responsible for approving this Policy and material exceptions. A Director or designated responsible person should maintain registers, coordinate risk-based checks and provide guidance.

Suspected bribery or circumvention must be reported promptly to any Director or another designated channel. Where the concern involves that person, it should be raised with a different Director. Good-faith reporters should be protected from retaliation as far as applicable law permits.

7 Records awareness and breaches

Due diligence, contracts, approvals, registers, invoices, evidence of services, expenses, reports and investigation outcomes must be accurate and retained in line with applicable law and the records policy. Off-book accounts and misleading descriptions are prohibited.

Training should be proportionate to exposure. Suspected breaches must be assessed promptly and may lead to withdrawal from a transaction, termination, contractual or disciplinary action, recovery of losses and referral for legal or regulatory advice.

8 Review

This Policy should be reviewed at least annually and when business geographies, public-sector exposure, intermediary use or applicable law changes materially.

Implementation note. This policy should be read with the other DE Trading corporate policies, transaction-specific approvals and the law applicable to the relevant contracting entity and transaction.