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Anti-Corruption Compliance Guidelines

Table of Content Introduction General Standards NBH Co.s Anti-Corruption Policy

NBH ANTI -BRIBERY AND CORRUPTION POLICY

Introduction and the importance of reportin concern!" NBH values its longstanding reputation for ethical behavior and integrity. Conducting business with a zero tolerance approach to all forms of corruption is central to these values, the NBH's image and reputation. NBH wrote this guide to help you avoid problems with corruption. This guide provides general rules and practical e amples where corruption and bribery might ta!e place and alerts where e tra caution is re"uired. The anti#corruption rules are comple , and in fact, the pressure to ignore them might be great. NBH Co. values re"uire full compliance with these laws. The policy below sets out the standards e pected of all NBH employees in relation to anti# bribery and corruption. $n particular, all employees must adhere strictly to relevant laws in this area, including %&' Bribery 'ct. The (olicy is also relevant for third parties who perform services for or on behalf of the NBH. The NBH e pects those persons to adhere to the (olicy or have in place e"uivalent policies and procedures to combat bribery and corruption. The (olicy should be read in the conte t of a number of other measures that the NBH has in place to ensure there is effective communication about anti # corruption issues in connection with its business. These include) *a+ (roviding training to employees on anti#bribery issues

*b+ ,riting to persons and companies associated with the NBH to set out the NBH's approach to anticorruption *c+ 'dditional steps to encourage all employees to be vigilant and to report any suspicion of bribery. $n this regard, the NBH promotes a number of channels of communication for employees to raise concerns as follows)

The NBH will ensure any concerns are investigated appropriately and any employee ma!ing a report in good faith shall suffer no detriment for doing so. The NBH will ta!e firm action against any individuals or other parties that it discovers are involved in bribery. 'ny breach of the (olicy by employees will result in disciplinary action under the -ross .isconduct provisions of the NBH's /isciplinary and /ismissal (rocedures which can include the sanction of summary dismissal in any case where an employee has been found to have paid or received a bribe. 0ailure by any employee to report corrupt activity by other persons can also result in disciplinary sanctions, especially where there is evidence that an employee has attempted to cover up or disguise another's wrongdoing. #ENERAL $TANDARD$ Corruption occurs when someone in a position of trust misuses that position in e change for personal benefit of any form. ,hile corruption is easy to define, identifying actual corruption can be difficult. 0or this reason we all have a responsibility to educate ourselves to recognize corruption and bribe acts and protect our business deals, such acts has so damaging effects on both companies and individual offenders. ,e are committed to insure compliance, even if it means that we might lose a bid.