CSR Performance Ltd Anti-Corruption Policy

CSR Performance Limited (“the Company”) recognises that Anti-Corruption Compliance is an integral part of its management function. The Company views this as a primary responsibility and to be critical to good business practice.

The Company Policy calls for continuous vigilance for any signs or indicators of corruption in its business activities and its business will be conducted according to the following principles:

We will:-

• Comply with all applicable laws and regulations in the countries in which our products are installed and used.
• Not, directly or indirectly, make any payment, or offer, or authorise or promise to pay, any Item of Value to any Government official or any commercial entity or individual for the purpose of improperly inducing or influencing such person or entity to act in any way to help any Client obtain or retain business or secure any improper advantage.
• The payment of any Facilitation Payment is expressly prohibited.
• Implement and maintain, adequate, proportionate and effective policies and procedures to ensure compliance with all applicable Anti-Bribery and Anti-Corruption Laws.
• Maintain detailed, accurate and up to date books and records of account showing all payments made by the Company. The Company shall ensure that such books and records of account are sufficient to enable the Company to verify its compliance with its obligations under the applicable Anti-Bribery and Anti-Corruption Laws. If requested by any Client in writing, the Company agrees to make such books and records of account available to the Client or its designee.
• Permit any Client and its third party representatives, on reasonable notice during normal business hours, but without notice in case of any reasonably suspected breach of this Policy, to audit the Company’s compliance with its obligations under the applicable Anti-Bribery and Anti-Corruption Laws. Such audit rights will be written in to Agreements with Clients and shall continue for five years after termination of such Agreements.
• If requested, provide a Client with any reasonable assistance to enable the Client to perform any activity required by any relevant governmental or agency in any relevant jurisdiction for the purpose of compliance with the applicable Anti-Bribery and Anti-Corruption Laws.
• Immediately report to a Client any request or demand for any improper financial or other advantage of any kind received by the Company in connection with the performance of its services to the Client. Reports of this nature will be communicated by email to the Client.
• Report to its Clients any material change in its ownership giving the Clients the right to conduct additional due diligence on such new beneficial owners or entities. Reports of this nature will be communicated by email to Clients.
• Not allow, or appear to allow, any personal, family or political connection of its employees, agents, contractors or consultants to improperly influence any decision making or judgment in the provision of the Company services. The Company shall not contact or knowingly meet with any Government official for the purpose of discussing activities relating to a Client, unless required by applicable laws or regulations, without the prior notification to the affected Client. Any actual, apparent or potential conflict of interest that becomes known to the Company must be reported promptly to the affected Client. Reports of this nature will be communicated by email to the affected Client.

It is also our aim that, with the total involvement and understanding of all our staff, and clear communications between the Company and its Clients, that the Company will at all times remain compliant with all Anti-Corruption laws and recognised standards of behaviour.