Statement on Bribery and Corruption

Introduction

Strawberry Star Group takes a zero-tolerance approach to bribery and corruption and we are committed to conducting our global activities free from any form of such behaviour. We also expect the same from any third parties providing services to or on behalf of Strawberry Star Group. The Strawberry Star Group Anti Bribery and Anti-Corruption Policy and Standards (ABC Policy) and the Strawberry Star Group Introducer Policy and Standards (Introducer Policy) extend to all Strawberry Star Group’s business dealings, and they are supported and endorsed by the Board of Directors, which has ultimate responsibility for their implementation. Our ABC Policy and our Introducer Policy are designed to help Strawberry Star Group and its employees comply with the UK Bribery Act 2010 and with applicable local anti-bribery and anti corruption legislation.

Strawberry Star Group ABC Policy and Standards

Strawberry Star Group’s ABC Policy apply to all Strawberry Star Group employees, and are designed to ensure that the Strawberry Star Group employees know how to identify and manage the legal, regulatory and reputational risks associated with bribery and corruption.

Under the ABC Policy, Strawberry Star Group employees are:

Consistent with this, Strawberry Star Group employees are:

The ABC Policy contains the minimum controls requirements that Strawberry Star Group employees must follow to comply with the ABC Policy. The ABC Policy provides more detailed requirements regarding, amongst other things, how to deal with facilitation payment requests, gifts & entertainment, charitable donations/community investments, commercial sponsorship, political donations, lobbying, third party relationships and mergers & acquisitions.

Strawberry Star Group Introducer Policy

In addition, due to the bribery and corruption risks associated with third parties who are engaged to generate or retain business or secure a business benefit for Strawberry Star Group, we have a standalone Introducer Policy. Third parties who are defined as “introducers” by Strawberry Star Group include senior advisers, lead generators, and certain other advisers. The Introducer Policy is designed to protect Strawberry Star Group against bribery and corruption risks, system and controls risks, reputational risk and wider legal and regulatory risks associated with these relationships. The Introducer Policy requires employees to risk rate and conduct due diligence on Introducers, obtain approvals for Introducers, and include ABC Policy related contract clauses in written agreements with Introducers. In addition, the Introducer Policy sets out an employee’s responsibilities for the on-going management of introducer relationships, including how to escalate breaches of the Introducer Policy and/or potential introducer related misconduct.

Consequences of Failing to Comply with the ABC and Introducer Policies

Failure to comply with the requirements of our ABC or Introducer Policies may lead to disciplinary action, up to and including dismissal or termination of employment.
 
This statement was approved by the board of “Strawberry Star Group” and its subsidiaries.