Anti-Bribery and Corruption Policy

Audentes Fortuna is committed to conducting business with the highest standards of integrity and ethics. This policy outlines our zero-tolerance approach to bribery and corruption in all forms.

Policy Statement

We prohibit any form of bribery, corruption, or unethical business practices. All employees, directors, contractors, and business partners must comply with this policy and applicable anti-bribery laws, including the UK Bribery Act 2010.

What is Bribery?

Bribery is the offering, giving, receiving, or soliciting of anything of value to influence the actions of an official or other person in charge of a public or legal duty. This includes:

• Cash payments or gifts
• Entertainment or hospitality
• Favors or services
• Political contributions
• Charitable donations made to influence decisions

Prohibited Activities

The following activities are strictly prohibited:

• Offering, giving, or promising bribes to anyone
• Requesting, accepting, or agreeing to receive bribes
• Facilitating payments to expedite routine government actions
• Making payments to third parties where there is a risk they may be used for bribery
• Engaging in any form of corruption or unethical business practices

Gifts and Hospitality

We recognize that legitimate business entertainment and gifts can be part of building relationships. However, all gifts and hospitality must:

• Be reasonable and proportionate
• Not be given to influence a business decision
• Be properly recorded and approved
• Comply with the recipient's organization's policies
• Not create a conflict of interest

Due Diligence

We conduct appropriate due diligence on all business partners, including:

• Third-party agents and consultants
• Joint venture partners
• Suppliers and contractors
• Any party acting on our behalf

Training and Awareness

We provide regular training to all employees on:

• Anti-bribery laws and regulations
• Our anti-bribery policies and procedures
• How to identify and report potential bribery
• Consequences of non-compliance

Reporting and Whistleblowing

We encourage employees and business partners to report any suspected bribery or corruption. Reports can be made:

• To your line manager or supervisor
• To our compliance officer
• Through our confidential reporting hotline
• Via email to compliance@audentesfortuna.co.uk

Investigation and Disciplinary Action

All reports of bribery or corruption will be:

• Investigated promptly and thoroughly
• Handled confidentially and professionally
• Result in appropriate disciplinary action if substantiated
• Reported to relevant authorities if required by law

Record Keeping

We maintain accurate records of:

• All gifts and hospitality given and received
• Due diligence on business partners
• Training records and certifications
• Investigations and their outcomes

Compliance Monitoring

We regularly monitor compliance with this policy through:

• Internal audits and reviews
• Risk assessments
• Employee surveys and feedback
• Third-party assessments

Consequences of Non-Compliance

Violations of this policy may result in:

• Disciplinary action up to and including termination
• Legal action and prosecution
• Damage to our reputation and business relationships
• Financial penalties and sanctions

Contact Information

For questions about this policy or to report concerns:

• Compliance Officer: compliance@audentesfortuna.co.uk
• Phone: +44 20 XXXX XXXX
• Address: London, United Kingdom