Anti-bribery and Corruption Policy

1. Flagstone Group Ltd (“Flagstone”) has a zero-tolerance approach to bribery and corruption and is committed to conducting business fairly, ethically and with integrity. As a result of this approach, Flagstone requires full compliance with the UK Bribery Act 2010 from all suppliers, and partners as well as its employees.
   
   Flagstone aims to create a strong culture where all employees act fairly, honestly, and openly. Our commitment to a zero-tolerance approach to bribery and corruption is demonstrated by:

   1. Setting out a clear Anti-Bribery and Corruption policy;
   2. Delivering Anti-Bribery and Corruption training to all employees on an on-going basis;
   3. Enabling employees to recognise and to report any suspicion of bribery, and providing them with suitable channels of escalation;
   4. Establishing a pre-approval process relating to the offering and accepting of gifts and entertainment, as well as maintaining a gifts and entertainment register;
   5. Conducting appropriate due diligence on third parties engaged by Flagstone;
   6. Ensuring that recruitment is fair and based on merit and suitability for a role. Hiring will not be used to influence any business decisions or to gain an unfair advantage for Flagstone;
   7. Thoroughly investigating any instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution; and
   8. Taking firm action against any individual(s) involved in bribery. Failure to adhere to Flagstone’s Anti-Bribery and Corruption Policy requirements may lead to disciplinary actions against an individual, up to and including dismissal or termination of a contract for services.

Further Clarification

Flagstone prohibits the offering, giving, solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company wherever they are situated. This is regardless of whether they are a public official or body, or a private person or company. This applies to any employee, agent or other person or body acting on behalf of Flagstone.

Flagstone will not tolerate any action(s) taken in order to gain any commercial, contractual or regulatory advantage in a way which is unethical, or in order to gain any personal advantage for the individual or anyone connected with that individual. This includes the provision of facilitation payments. If any individual is in doubt as to whether a potential act constitutes bribery, the matter should be referred to Flagstone’s Compliance and Senior Management team before proceeding.