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The Bribery Act

Code of Conduct:

The Board of Directors has produced a Code of Conduct for businesses in the Walker Greenbank PLC Group to adopt.

The objective of the Code is to protect the reputation of the Group and its employees.

This Code is of substantial importance as it will govern the way in which the businesses of the Group treat the issue of bribery.

The Board is committed to ensuring the highest legal and ethical standards.

The Code of Conduct:

We will conduct our business in an honest way without resorting to acts of bribery to obtain an unfair advantage.

We will set out the standards we expect from our employees in their internal and external dealings with our colleagues, customers and third parties

We will conduct every aspect of our business with integrity, honesty and openness.

We will ensure that no employee or business will accept or give a bribe, facilitation payment or other improper payment.

We will not support, tolerate or condone any form of bribery.

We will ensure that adequate procedures are in place to prevent the risk of bribery.

We will comply with all applicable export control laws and sanctions when conducting business around the world.

We will ensure that accepting or giving any entertainment or gift that is designed to influence business decisions is not acceptable.

We will aim to develop strong relationships with our suppliers based on trust, understanding and respect.

We will expect those we do business with including agents, distributors, subsidiaries, intermediaries, consultants and contractors in the UK and overseas to adhere to principles consistent with our own.

We will comply with the laws and regulations wherever we do business.

We will expect all employees to behave respectfully and honestly in all their dealing with customers in accordance with the principles in this code.

We will ensure that we purchase a range of goods required for the operation of our business and rely upon a number of key suppliers; good working relationships with our suppliers are important for the success of our business.

We will always encourage employees to report any concerns regarding bribery or corruption through the Group’s Whistleblowing policy.