Governance @ Captivite Consulting Ltd

1. POLICY STATEMENT

1.1. It is Captivite's policy to conduct all of its business in an honest and ethical manner. Captivite takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships. It is the goal of Captivite to avoid acts which might reflect adversely upon the integrity and reputation of the Company.

1.2. Individuals involved in corrupt activity will be subject to disciplinary proceedings. Further, if Captivite or any of its employees or associated persons (e.g. contractors, agents or subsidiaries) is found to have taken part in corruption, Captivite could face legal sanctions, and this could seriously damage its reputation both in the eyes of the public and of clients. Captivite therefore takes its legal responsibilities very seriously.

1.3. Captivite is committed to upholding all laws relevant to countering bribery and corruption in each of the jurisdictions in which it operates. As the anti-corruption laws of the UK, US and Canada have extraterritorial application, Captivite, its employees and associated persons will be bound by the most stringent requirements of these laws in respect of its conduct in all jurisdictions they operate, even if such conduct would otherwise be permitted by the local law of a particular jurisdiction.

1.4. The purpose of this Policy is to:
- set out the responsibilities of Captivite, and all individuals who work for Captivite Consulting, in observing and upholding the Company's position on bribery and corruption; and
- provide information and guidance to those individuals working for Captivite Consulting on how to recognise and deal with bribery and corruption issues.

1.5. In this Policy, "third party" means any individual or organisation with whom you may come into contact during the course of your work for Captivite, and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

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