Anti Bribery & Corruption Statement

At Terra Firma (South), Anti-Bribery & Corruption is embedded in our company philosophy – ‘We expect honesty, integrity and fairness in all aspects of our business by whoever, wherever’.

We are committed to complying with our obligations under applicable legislation, including the Bribery Act 2012.

Terra Firma (South) expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. We expect the same approach to doing business from all our contractors and suppliers. Pursuant to this Terra Firma (South) will not tolerate bribery or corruption in any form and has a ‘zero tolerance’ approach to any breach of this policy.

Terra Firma (South) and its employees will never seek, accept or give a bribe, facilitation payment, kickback or other improper payment. We also ensure that we operate with appropriate transparency in all our business dealings. We will take appropriate steps to ensure that:

1. We do not, directly or indirectly, offer, promise, give, accept or demand a bribe or other undue advantage (including excessive gifts and hospitality) in order to obtain or retain business, or gain any other improper advantage.

2. We do not offer, nor give in to demands, to make illicit or illegal payments to anybody that we do business with.

3. We engage and remunerate third parties only for legitimate services and adopt appropriate transparency in our approach.

4. We promote employee awareness of, and compliance with, company policies against bribery and corruption through appropriate dissemination of our own procedures (including disciplinary procedures) policies and training programmes on induction and subsequently.

5. We adopt management control systems that discourage bribery and corruption, and adopt transparent financial and tax accounting and auditing practices.

6. We raise awareness of the need to combat bribery and corruption with our business partners by publication of this Policy and (where appropriate) relevant contractual provisions and support initiatives designed to reduce the risk of bribery and corruption.