1. Anti-Bribery and Corruption Procedures relating to Gifts, Meals, Entertainment and Travel

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1 Go Transit Proprietary Limited t/a PRIMEDIA UNLIMITED and its Subsidiaries Hereinafter referred to as Unlimited Anti-Bribery and Corruption Policy OBJECTIVES The objective of this policy is to set out Unlimited s and Unlimited s employees responsibilities, in observing and upholding a valid position on bribery and corruption. The purpose is also to provide information and guidance to employees on how to recognise and deal with bribery and corruption issues CONTENT 1. Gifts, Meals, Entertainment and Travel 2. Donation and Sponsorships 3. Facilitation Payments and Emergency Payments 4. Contractual Relationships 5. Investigations (Whistle-Blowing) 1. Anti-Bribery and Corruption Procedures relating to Gifts, Meals, Entertainment and Travel Unlimited does not give or receive gifts, meals, travel or entertainment that could influence or appear to influence our objectivity in conducting our business or could influence the objectivity of others meeting their responsibilities. In the event that gifts are exchanged or meals, travel or entertainment is provided or received that could not influence objectivity, it is our approach to declare and document such gifts, travel, meals or entertainment in a gift, meals, entertainment and travel register ( Gratuities Register ), to be maintained by the executive committee and/or the board of directors of the relevant Unlimited division/subsidiary.

2 The following actions regarding gifts, meals, travel and/ or entertainment are not allowed by Unlimited, and refer to all suppliers, potential suppliers and customers: Soliciting gifts, gratuities, favours, courtesies, entertainment, travel, loans or cash payments from suppliers, potential suppliers and customers; Giving or receiving gifts of cash or cash equivalents; Providing a gift, meal, travel or entertainment to influence a tender adjudication; Channelling business to specific service providers or suppliers with the intention of receiving something in return; Accepting or receiving more than one gift from the same supplier, client or third party in any three month period, in any one Unlimited subsidiary/division; Giving a gift to the same supplier, client or third party more than once in any given three month period, in any one Unlimited subsidiary/division; Accepting or receiving entertainment from the same supplier, client or third party in any three month period; and Entertaining the same supplier, client or third party more than once in any given three month period, in any one Unlimited subsidiary/division. The following actions regarding gifts, meals, entertainment and travel are required by Unlimited: Giving and Receiving of Gifts Subject to the over-arching guidelines and principles detailed above, the following policy applies with regard to the giving and receiving of gifts A promotional gift (e.g. Unlimited-branded item, such as a hat, paper weight, calendar and similar inexpensive, branded items) with a value of less than the equivalent of R750 may be provided to or accepted from a service provider, supplier or other third party without prior written approval, providing that such gift adheres to the requirements set out in this procedure. Gifts of a value less than R750 do not need to be recorded in the Gratuities Register; A promotional gift with a value of more than R750, may only be provided to a service provider, supplier or other third party with prior written approval by the Subsidiary/Divisional Manager of the relevant Unlimited division/subsidiary. The receipt of a promotional gift with a value of more than the equivalent of R750 must be declared to the Subsidiary/Divisional Manager of the relevant Unlimited division/subsidiary within two business days from receipt of the gift for the Manager s retrospective approval of the acceptance of the gift and recorded in the Gratuities Register. The gift given or received that has a value of more than R750 must be declared in the Gratuities Register and the written approval, provided by the Divisional/Subsidiary Manager of the relevant Unlimited division/subsidiary, must also be retained in the Gratuities Register. A promotional gift with a value of more than R5 000, may only be provided to a service provider, supplier or other third party with prior written approval by an executive of executive committee/board of

3 directors of the relevant Unlimited division/subsidiary. The gift must be declared in the Gratuities Register prior to giving the gift and the written approval, provided by the executive of the executive committee/board of directors of the relevant Unlimited division/subsidiary, must also be retained in the Gratuities register. Employees of Unlimited may not accept gifts with a value of more than R5 000 from service providers, suppliers or third parties without the prior written approval by an executive of executive committee/board of directors of the relevant Unlimited division/subsidiary. The gift must be declared in the Gratuities Register prior to receiving the gift and the written approval, provided by the executive of the executive committee/board of directors of the relevant Unlimited division/subsidiary, must also be retained in the Gratuities register. Meals or entertainment Subject to the over-arching guidelines and principles detailed above, the following policy applies with regard to the giving and receiving of meals or entertainment: Meals or entertainment with a value of less than R750 per person may be provided to or accepted from a service provider, supplier or other third party without prior written approval, provided that such meal or entertainment adheres to the requirements set out in this procedure. Meals or entertainment of a value less than R750 do not need to be recorded in the Gratuities Register Meals or entertainment with a value of more than R750 per person may only be provided to or accepted from a service provider, supplier or other third party with, as far as is practically possible, prior written approval by the Divisional/Subsidiary Manager of the relevant Unlimited division/subsidiary. The meal or entertainment must be declared in the Gratuities Register within 2 days of providing or receiving the meal or entertainment and the written approval, provided by the Divisional/Subsidiary Manager of the relevant Unlimited division/subsidiary, must also be retained in the Gratuities Register; Meals or entertainment with a value of more than R5 000 per person, may only be provided to a service provider, supplier or other third party with prior written approval by an executive of the board of the relevant Unlimited division/subsidiary. The meal or entertainment must be declared in the Gratuities Register where possible / practical and the written approval, provided by an executive of the board of the relevant Unlimited division/subsidiary, must also be retained in the Gratuities Register. Employees of Unlimited may not accept entertainment with a value of more than R5 000 from service providers, suppliers or third parties without the prior written approval by an executive of executive committee/board of directors of the relevant Unlimited division/subsidiary. The meal or entertainment must be declared in the Gratuities Register prior to receiving the meal or entertainment and the written approval, provided by the executive of the executive committee/board of directors of the relevant Unlimited division/subsidiary, must also be retained in the Gratuities register.

4 Unlimited will not pay for meals or entertainment of the spouse, spousal equivalent or close business partner of a service provider, supplier or other third party unless approved in writing by an executive of the board of the relevant Unlimited division/subsidiary. As far as practically possible the meal or entertainment of the spouse, spousal equivalent or close business partner must be declared in the Gratuities Register prior to providing the meal or entertainment and the written approval, provided by the executive of the board of the relevant Unlimited division/subsidiary must also be retained in the Gratuities Register. Travel Unlimited may pay for the reasonable travel expenses, including airfare, hotel accommodation, meals and other incidentals of suppliers, service providers or other third parties under the following circumstances: The reasonable travel expenses are incurred in the promotion, demonstration or explanation of Unlimited goods or services; or The reasonable travel expenses are incurred in the execution or performance of a contract. The reasonable travel expenses are incurred in course of an approved marketing initiative that a number of clients, suppliers, service providers or other third parties are attending. Any travel expenses paid for by Unlimited must have a proper business purpose and must be approved in writing by the Unlimited subsidiary MD/CEO that is applicable before any expense is incurred. The following specific procedures will govern the payment of travel and accommodation to third parties: Travel must be directly between the residence or place of business of the third party and the location the third party is visiting for business purposes. Unlimited will not pay for any shopping excursions, side trips, leisure activities or entertainment as part of the third party s trip that do not form part of the Primedia Unlimited business purpose; Payment for travel and accommodation will be made directly to the relevant accommodation or travel service providers. Expenditure for meals, not included in the accommodation and incidental expenses such as taxi fares and dry cleaning, will be provided by way of a per diem to the third party. Such per diem will not exceed the equivalent of R This amount may be higher in the case of overseas travel in this instance, the relevant Unlimited subsidiary MD/CEO must approve the higher per diem in writing prior to the overseas trip being taken. Unlimited will not pay for travel or accommodation for family members or close business associates of the visiting third party. In any instance where circumstances prevent an Unlimited employee from obtaining the required written pre-approval, verbal pre-approval must be obtained from the relevant Divisional/Subsidiary Manager and written approval must be obtained within 2 business days after the providing or receiving of the unapproved gift, entertainment, meal or travel. Reasons must be provided in writing as to why

5 the required pre-approval was not obtained. The gift, meal or entertainment must also be entered in the Gratuities Register. In instances where verbal pre-approval was not obtained, the procedure for ratification, set out above must be followed and reasons for the fact that verbal approval was not obtained, should also be provided in the application for subsequent approval. 2. Donations and Sponsorships Unlimited does not give or receive donations or sponsorships that could influence or appear to influence our objectivity in conducting our business or could influence the objectivity of others meeting their responsibilities. Political contributions Political contributions include making payments or providing benefits to government officials or political parties. It also includes participating, in whatever manner, in party politics and the provision of advertising services at less than market rates. It is the policy at Unlimited not to make political contributions of any kind and to not become involved in party politics in any way. Employees are allowed to be involved in party politics in their private capacity and outside office hours. However, employees are not allowed to create the impression in any way that they are acting on behalf of Unlimited when doing so. Donations Unlimited may only make donations for bona fide charitable purposes. The rules below regarding donations are not applicable in the case of Unlimited approaching a third party charity to make a contribution the rules are applicable to third parties that make a request for a donation to Unlimited. No donations will be made to individuals, unless approved by the Unlimited CEO. Donations will not be made by means of a cash payment. All donations will be made via cheque or electronic fund transfer. The procedure to be followed regarding donations is as follows: The third party requester will be required to complete a form, providing background information regarding the organisation requesting the donation, the donation required, the amount of the donation and the intended application of the donation; The recipient of the request within Unlimited will provide supporting information regarding the requestor and any available background information; The request will be submitted to the Divisional/Subsidiary Manager of the relevant Unlimited division/subsidiary for written approval.

6 In instances where the requested amount is above the equivalent of R (ten thousand Rand) or in instances where the donation will be provided to an individual, the request, with documentation, will be submitted to the Unlimited CEO for final written approval. Should either an executive of the relevant Unlimited Subsidiary/Division and/ or the Unlimited or Primedia Financial Executive be of the opinion that either the documented information or the information in the media or on social networks may indicate an elevated corruption risk, they may either deny the request or order that the relevant entity requesting the donation be subjected to due diligence by a third party due diligence service provider, who will be requested to submit a written due diligence report to Unlimited s Financial Executive. Based on the information contained in this report and documented information, an executive of the relevant Unlimited Division/Subsidiary will consider and approve or decline the request for a donation in writing; Upon receipt of the required approval, the donation will be provided, as approved. The recipient will be required to acknowledge receipt of the donation in writing; and Documented information and any due diligence report obtained, the written approvals and the Acknowledgement of Receipt will be retained for five years for audit purposes. Where the recipient of the donation is an organisation approved by the Commissioner under section 18A of the Income Tax Act, a section 18A certificate must be obtained from the recipient. Sponsorships A Sponsorship is a monetary or in-kind contribution by Unlimited to support an activity or initiative organised by a third party in exchange for the public display of an Unlimited business s brand or another business benefit. The approval process, set out above for a donation will be followed and written approval for all sponsorships from both an executive of the relevant Unlimited Subsidiary/Division and the Unlimited Group Financial Executive will be required. It is specifically noted that sponsorships for any of the following organizations is exempted from the donation process, where a sponsors hip for one of these organizations only requires approval of the relevant Unlimited divisional/subsidiary MD/CEO: South African Council of Shopping Centres, International Council of Shopping Centres, Advertising Benevolent Fund, Advertising Media Association of South Africa, Advertising Media Forum, the Creative Directors Circle, the AAA School of Advertising, the Red & Yellow School, the Vega School, Association of Communication Agencies and the Advertising Standards Authority. 3. Facilitation Payments and Emergency Payments

7 Facilitation payments A facilitation payment can be defined as any facilitating or expediting payment to an official, the purpose of which is to expedite or to secure the performance of a routine action by such official. Although such small payments or gifts to officials to incentivise them to perform their duties are permitted in terms of certain laws, it should be noted that such payments or gifts are prohibited by the Prevention and Combating of Corrupt Activities Act (PRECCA), Act 12 of Unlimited, as a South African company is required to comply with PRECCA. Unlimited does not allow facilitation payments or gifts to be made for, or on behalf of Unlimited or during the course of Unlimited s business. Making a facilitation payment or giving such gift is a contravention of this policy and, except under circumstances set out below, will be a dismissible offence. Emergency payments Unlimited recognises that situations arise where employees life, body, possessions, safety or honour may be threatened and where the making of a payment may be the only way to escape the situation. Unlimited acknowledges that employees may make emergency payments under circumstances where it is the only reasonable way to protect their life, body, possessions or honour. This allowance will only be valid if the situation meets all the requirements, set out below and where the employee adhered to all the requirements of this policy. The requirements to classify a payment as an emergency payment are as follows: The action that the employee is being threatened with must be illegal. An employee cannot make a payment under this policy to escape a legal action or detention against him or a person with him or a legal retention of possessions; The threatened action must be aimed at the employee or a person travelling with the employee on Unlimited s business; The threatened action must be aimed at the property of the employee, a person travelling with the employee on Unlimited s business or the property of Unlimited The threat must be imminent or ongoing. A payment cannot be offered in anticipation of a potential threat; and Making the required payment must be the only reasonable way to escape the threat.

8 Procedure to be followed subsequent to making an emergency payment Where an emergency payment was made under duress or an item was given under duress, the person forced to make such a payment or gift must submit a sworn affidavit, addressing the following, to the Divisional Risk and Compliance Manager of the relevant Unlimited division/subsidiary upon his/her return to the office where he/she is based: The date, time and location of the request for payment or gift; The date, time and location when the payment or gift was handed to the official (if different from the date, time and place of the request); The name, rank and capacity of the person who requested the payment; The amount/ item and value of the item requested; The circumstances under which the payment was requested; The direct or implied threat experienced by the person the demand was made to; The potential danger or loss foreseen by the person the demand was made to at the time of the demand; Why no other solution was available to the person the demand was made to; and The result of the demand being met. A payment made under circumstances that will qualify as an emergency payment as defined above, must be reflected in the financial records of Primedia as an emergency payment and a certified copy of the sworn affidavit must be retained as the relevant source document. The original affidavit must be lodged with the Unlimited Divisional Financial Executive, who will retain such affidavit for a period of 5 years. The Unlimited Divisional Risk and Compliance Manager will also provide a copy of the affidavit to any enforcement body or police force where it is possible to do so without endangering the lives of Primedia employees. 4. Contractual Relationships Undertaking required from parties contracting with Unlimited Any contract, concluded between Unlimited and a third party, will contain clauses, stating the following: (The third party) hereby undertakes to adhere to all Anti-Bribery and Corruption legislation that is or may become relevant to Unlimited during the duration of this contract. (Third party) agrees to adhere to all requests issued by Unlimited that may result from adherence by Unlimited to the relevant Anti-Bribery and Corruption legislation. Rights to be reserved on behalf of Unlimited in agreements with third parties Where a party acts on behalf of Unlimited or disburses funds for the benefit of Unlimited, a clause should be included in the contract with such party that will provide Unlimited with audit rights

9 regarding all payments made by the third party during the course of the execution of the contract with Unlimited. Unlimited should, in all contracts, reserve the right to exit the contract immediately without a penalty clause, should a prima facie case of bribery or corruption be levelled against the third p arty, whether the case relates to business performed on behalf of Unlimited or not. Payment terms not allowed in contracts concluded on behalf of Unlimited The following payment terms will not be agreed to in contracts, concluded on behalf of Primedia: Cash payments; Payments into an account that is not held in the name of the service provider; Payments to a bank account in a country other than the country where the services are rendered; Payments to a third party on behalf of the service provider; Advances on commission to any service provider being remunerated on a commission basis 5. Investigations (WhistleBlowing) Investigation procedure Staff members within Unlimited identifying suspected fraud, commercial irregularity or unethical conduct are to notify their Subsidiary/Divisional Risk & Compliance Manger. They may also make a report via the Primedia whistle-blowing Hotline. The relevant Subsidiary/Divisional Risk & Compliance Manager is to be notified at the earliest opportunity where a report is made through the whistle-blowing hotline number (Primetips). A Subsidiary/Divisional Risk & Compliance Manager to whom the report is first made directly or via the whistle-blowing hotline is to inform the Unlimited Divisional Board of Directors/Executives immediately of the allegation and then secure all relevant documentation and records, or in the case of electronic systems, secure source documents, printouts and relevant reports. Should the matter be criminal in nature, proper procedures need to be adhered to in order not to contaminate or destroy any evidential material. External consultants may be used for this purpose. In instances where allegations of corruption is raised, the Primedia Group Head of Legal must be consulted to establish whether an external legal firm should be appointed to oversee the investigation to ensure that legal privilege is vested and that working papers and reports cannot be summarily seized in instances of regulatory action. The manager assigned responsibility for conducting or coordinating the investigation is to submit a written report, containing details of the circumstances and recommendations to the Unlimited CEO and the Primedia Group Head of Legal.

10 Once an investigation has begun, consideration needs to be given to whether it would be appropriate in the circumstances to suspend the subject on full pay until the issue is resolved. Advice should be sought from the Human Capital department in this regard. After consideration by the Subsidiary/Divisional Risk & Compliance Manager of the relevant Unlimited division/subsidiary, the investigator may refer the matter to the relevant Police Station for further investigation, should it be deemed necessary. The Group Head of Legal will maintain a register of all fraud, theft, corruption and irregular losses reported and referred for further investigation. The Subsidiary/Divisional Risk & Compliance Manager of the relevant Unlimited operation will be responsible for recovering any funds owed to Unlimited as a result of court orders or private treaties with persons found to have been involved in irregular conduct.