Flint Group Anti-Bribery and Corruption Policy

Flint Group Anti-Bribery and Corruption Policy

I Introduction Integrity is one of Flint Group s guiding principles and it is important that every employee and company connected to Flint Group understands our standards and expectations. This policy on Anti-Bribery and Corruption helps to give this clarity. Flint Group s reputation for acting responsibly has played a critical role in our success as a business and is essential to the sustainability of our business going forward. We know that Flint Group employees embrace these high standards and want to work for a Company that maintains such high standards. Our culture is defined by what we do rather than what we write or say but it is important to have clear policies and guidelines so that our employees can then use their judgement and common sense to do what is right in the right way. We also have people in Flint Group who can provide guidance and advice in the event of any doubt. Our reputation stems from our five guiding principles, which define the essence of how we behave and how we do business: - Our customers are the focus of all that we do; - Everyone contributes to our success; - Integrity will never be compromised; - Continuous improvement drives performance and supports our aspirations to achieve excellence; - Leadership and teamwork are prerequisites for achieving our goals. These values are expressed through the principles and standards of conduct set out in our Code of Conduct. This is available at www.flintgrp.com, on the Company s intranet and from the site managers. The Code of Conduct is supplemented as necessary with more detailed policies and procedures addressing specific areas of compliance. The purpose of this Anti-Bribery and Corruption Policy is to set out Flint Group s policy on compliance with applicable laws related to bribery and corruption and to provide guidance on the prevention, detection and reporting of bribery and corruption. If you have any questions about Flint Group s Anti-Bribery and Corruption Policy, please contact your line manager in the first instance. The Legal Department will also be pleased to answer any questions that may arise. These are important laws and there are serious consequences for the Company and any individuals who engage in corrupt activity. II Scope and Purpose of Policy This Policy applies to Flint Group directors, officers, employees (including temporary or contract employees) and everyone with whom we do business, including agents, distributors and other third parties acting for or on behalf of Flint Group (e.g. consultants, lawyers, tax advisors, etc.). All such persons are required to comply with all laws, domestic and foreign, prohibiting improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public section customers and suppliers. This Policy seeks to give practical examples of acceptable and non-acceptable behaviours to ensure compliance with all applicable anti-corruption laws, including most notably the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, which are two broad anticorruption laws applicable to Flint Group s business. This Policy will be communicated in a form appropriate to the role and function of each employee. III General Policy Flint Group does not engage in or tolerate any form of bribery or corruption (whether directly or through third parties) in any part of the world in which we operate. Bribery and corruption offences present serious risks for every business. Breaches of bribery and corruption laws can lead to very large fines for companies and individuals, and imprisonment for individuals. The enforcement of bribery and corruption laws in many countries is increasingly stringent. These laws reach activities undertaken by a company through its employees, or third parties acting on its behalf, across various international jurisdictions. Bribery of Government Officials. Flint Group prohibits making or causing to be made the offer, promise, gift or authorisation of payment or other benefit, favour or hospitality whether directly or indirectly to: - Any government official to influence or with the intention of influencing any action, inaction or decision to obtain or retain business or a business advantage for Flint Group; or - Anyone else in order to induce or with the intention of inducing that person, or any other person, to perform, or reward that person for performing, his or her job improperly. A government official includes any public official or officer or employee of a 2 F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y

government anywhere in the world at any level; government-owned or controlled entities, such as state-owned enterprises, universities or utility companies; political parties; or public international organisations, such as the World Trade Organization. Commercial Bribery. Flint Group also does not tolerate the offering, making, requesting, or receiving of payments or payments in kind (gifts, favours, charitable donations, etc.) to influence individuals to award business opportunities to Flint Group or to make a business decision in Flint Group s favour, or which has the intention that in consequence a function should be performed improperly. Flint Group s objective is to compete in the marketplace on the basis of superior products, services and competitive prices. Commercial bribery for the purpose of continuation of existing business or to obtain any new business is not acceptable and is prohibited in all cases. This Policy does not prohibit the granting of legitimate industry-practice negotiated purchase prebates, rebates, bonus payments to customers or industry-practice customer finance arrangements with legal entities or the owners of such legal entities. In summary, the Company will not authorise or be a party to any illegal, unethical, or improper payments or benefits in kind in circumstances where a third party could reasonably perceive that a payment s purpose is to win or retain business, to influence business decisions or to secure the improper performance of a recipient s duties. See Appendix 1 for examples of conduct that would involve breaches of this policy. Remember: - A bribe does not have to be cash it can be any non-cash benefit, such as the offer of tickets to a sporting event or the use of holiday accommodations. - The person who receives the bribe is as guilty as the person who offers it, even if the bribe was unsolicited. - A bribe may still be a criminal offence under US, UK and other countries laws, even if it is committed overseas and irrespective of whether it is accepted under local custom. Flint Group requires that its employees comply with the specific prohibitions set forth in this Policy. Flint Group also expects its employees to exercise common sense and judgement in assessing whether any conduct or arrangement could be perceived to constitute bribery, corruption or otherwise inappropriate conduct. If an employee has any concerns regarding any form of proposed conduct or arrangement in which they are asked to participate or to which they are otherwise exposed, they must seek further guidance from their line manager or the Legal Department, or use the Company s Ethics and Integrity Hotline. All individuals subject to Flint Group s Anti-Bribery and Corruption Policy must promptly report any attempted, actual or suspected instances of non-compliance with the Policy using one of the reporting channels described in Section X below. No one should turn a blind eye to actual bribery attempted bribery, or warning signs that might suggest bribery. Each employee, director, officer, third party and anyone else acting for or on behalf of Flint Group has a responsibility to ensure that Flint Group is not involved in bribery or corruption. This responsibility applies equally to all of our business transactions throughout the world, irrespective of any perceived customary or required local practices. If you report a violation or suspected violation and appropriate action is not taken, you must contact Flint Group s General Counsel or Senior VP - Integrity and Compliance. Flint Group will investigate all reports made and will not tolerate any kind of retaliation for reports or complaints made in good faith. To the contrary, Flint Group protects all reporters, and employees are expected to cooperate in internal investigations of misconduct. IV Conflicts of Interest As a Flint Group employee, you are expected to make decisions concerning Flint Group s business based upon Flint Group s best interests. This means that you cannot consider whether the decisions you make will provide an additional benefit (or detriment) to you or an immediate relative (or close business associate). It also means that you may not use information or a business opportunity obtained in conducting company business to gain a financial advantage or benefit for yourself or an immediate relative (or close business associate). In the event that you find yourself being offered a gift or making a business decision that may involve another business or financial interest, whether already disclosed or not, you are expected to contact the Legal Department. Similarly, as a Flint Group employee, you should never compromise the decisionmaking process of a customer or prospective customer by providing or promising a personal benefit that may appear as an improper incentive to those making the business decision. V Anti-Bribery Laws Corruption can arise in many types of business activities. Bribes may be given to influence behaviour and may come in the form of money, privileges or an object of value. Government officials may be motivated to take bribes for personal gain in exchange for using their official position in favour of the bribing party. See Appendix 2 for helpful information and links to find more detail on relevant legislation. F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y 3

VI Helpful Definitions and Policies on Specific Activities A. Helpful Definitions Bribe: Anything of value given in an attempt to affect a person s actions or decisions in order to gain or retain a business advantage. Anything of value includes cash, entertainment, or other gifts or courtesies. Corruption: The misuse of a public office or power for private gain, or the misuse of private power in relation to business outside the realm of government. Theft: Stealing company property, money, colleagues property/money. Facilitation Payments: Payments to a government official for routine governmental action (such as processing papers, issuing permits, etc.) in order to expedite performance of non-discretionary duties (i.e. action they are already bound to perform). Government Official: Any public official or officer or employee of a: (a) government anywhere in the world at any level, (b) government-owned or controlled entity (e.g., state-owned enterprises, universities or utility companies), (c) political party, or (d) public international organisation (e.g., the World Trade Organisation). Kickbacks: The return of a sum already paid or due as a reward for awarding or furthering business. State-Owned Entities: A State-Owned or State-Controlled entity ( SOE ) is an entity in which the government of any non-us country (either as one agency or collectively through many different agencies or instrumentalities) holds equity interests exceeding 30% in the entity. B. Policies Related to Specific Activities The areas of business where corruption, including bribery, often occurs include: - Gifts, Entertainment and Hospitality - Third-Party Intermediaries - Payments to secure regulatory approval (which includes facilitation payments ) - Procurement Process 1.Gifts, Entertainment and Hospitality Flint Group s Gifts and Entertainment Policy reflects the Company s commitment to ensuring that the acceptance or offering of gifts and entertainment is reasonable and appropriate, and subject to managerial review. Gifts and entertainment given and received as a reward or encouragement for preferential treatment are not allowed. In certain circumstances, the giving and receiving of modest gifts and entertainment is acceptable. A business meal, for example, can provide a relaxed way of exchanging information. Nonetheless, depending on their size, frequency and the circumstances in which they are given, they may constitute bribes, political payments or undue influence. How do you know if an offered gift, entertainment or hospitality by Flint Group or to Flint Group is acceptable? First, take a step back and ask yourself the following: - What is the intent? Is it to build a relationship, or is it something else? - How would it look if these details were on the front page of a newspaper? - What if the situation was reversed and a Flint Group competitor was giving the gift? - Would it seem improper or unfair to you? - Is it in line with the Company expenses and Gift policies? - Does it pass the test of reasonableness? If you find it difficult to provide a comfortable answer to one of the questions above, ask your manager and seek written permission. Further, if you are unsure if you should accept something of value, ask your manager and seek written permission. If your manager is participating in the arrangement, seek a higher-level manager or contact the Senior VP Integrity and Compliance. As a general matter, Flint Group employees and third parties should not directly or indirectly provide gifts or hospitality to, or receive them from, government officials without the prior written approval of the Flint Group Legal Department. Services and favours that include the provision of cash, travel or other benefits cannot be given directly or indirectly to government officials under any circumstances. - Political, Community and Charitable Contributions 4 F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y

2.Third-Party Intermediaries Each employee, as an individual, and Flint Group can be held criminally liable for improper payments by third parties acting on behalf of the Company ( Intermediaries ). For this reason, Flint Group policy requires that you follow the steps outlined in the Company s Third Party Due Diligence Policy when obtaining the services of Intermediaries in connection with Flint Group s business. These steps include due diligence procedures to be performed before engaging Intermediariesand certain contractual provisions that must be included in the relevant Intermediary agreements. The types of Intermediaries that are subject to this policy include, but are not limited to: - Flint Group s agents; - sales representatives; - distributors; - consultants; - customs brokers or logistics providers; - joint venture partners. In general, before entering any contract with an Intermediary subject to this Policy, you must first conduct and document a reasonable due diligence investigation into the background, reputation and business capabilities of the Intermediary. Once approval has been granted to proceed with contracting, every Intermediary must enter into a written agreement with Flint Group that includes commitments to comply with applicable anti-bribery laws. Intermediaries will also be asked to provide periodic certifications of compliance with applicable anti-bribery laws and Flint Group s Code of Conduct. A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, with no parties having the unfair advantage of separate, prior, closed-door negotiations for a contract where the bidding process is intended to be open to all qualified bidders and where the sealed bids are open for scrutiny and are chosen on the basis of price and quality. 4.Political, Community and Charitable Contributions Flint Group prohibits the making of direct or indirect contributions to political parties from Company funds. Contributions made by Flint Group to community projects or charities need to be made in good faith and in compliance with our Code of Conduct, this Anti-Bribery and Corruption Policy, and all relevant Flint Group policies and procedures. Caution should be exercised to ensure that charities are not being used as a cover for political purposes, or to channel improper payments to government officials or to other third parties for corrupt purposes. 5.Facilitation Payments Government officials sometimes request payments, gifts or other things of value to expedite or facilitate routine, non-discretionary government actions (e.g. obtaining utility services or visas, issuing permits or processing certain papers). Regardless of local practices, Flint Group does not allow under any circumstances the making of such facilitation payments. If a government official requests a facilitating payment, you should not pay it, but instead should immediately report the request to your manager or through one of Flint Group s other reporting channels. Facilitation payments do not include payments to the local government authority of fees fixed under local law or regulations. Flint Group recognises that, in exceptional circumstances, the health, safety and security of employees faced with a demand for a facilitation payment may be at risk. Employees should refer to the Company s Security Guidance for advice on the steps to be taken in such exceptional circumstances. 3.Procurement Process You must follow Flint Group processes and adhere to the system of internal controls regarding supplier selection. Supplier selection should never be based on receipt of a gift, hospitality or payment. When supplier selection is a formal, structured invitation for the supply of products or services (often called a tender ), it is most important we maintain documentation supporting our internal controls. In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption. VII Mergers, Acquisitions and Joint Ventures From time to time, Flint Group will engage in business transactions such as mergers, acquisitions and/or joint ventures. As part of due diligence process, and prior to the execution of any such transaction, Flint Group will engage in a corruption review on the target or potential JV partner. Documentation concerning such corruption review shall be maintained by the Legal Department. F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y 5

VIII Books and Records Maintaining the integrity of Flint Group s accounting records is essential for many reasons, including compliance with anti-corruption laws. Flint Group employees must always ensure that any payments made in the course of doing business: - reflect the actual value of the services provided; - are made for a proper business reason; - are made to legitimate service providers; - are accurately and completely recorded; - meet the requirements of the laws in the US, UK, and other countries where we do business. Payments and expenses must never be hidden or purposefully recorded inaccurately: a practice which can often go hand-in-hand with corrupt payments. To prevent such practices, consistent with applicable anti-corruption laws, Flint Group requires detailed and accurate transaction records. All receipts and expenditures must be prepared and maintained with strict accuracy and completeness, supported by documents that accurately and properly describe the transactions or expenditures. The falsification of any book, record or account of Flint Group, and the submission of any false personal expense statement or claim for reimbursement of a nonbusiness personal expense, is prohibited. No accounts or payments may be kept off book to facilitate or conceal any dealings with third parties, improper or otherwise. If you become aware of any conduct by anyone working for or on behalf of Flint Group that you believe in good faith to be in violation of this Anti-Bribery and Corruption Policy, you should report such conduct promptly, fully and objectively through an appropriate channel. Flint Group has established several alternative channels to permit you to select the reporting channel with which you are most comfortable. For instance, you may report violations by: - speaking with your manager or supervisor; - using formal internal processes, such as the formal grievance process; - speaking with Human Resources personnel; - contacting Flint Group Corporate Compliance personnel or the Legal Department; - calling or writing to Flint Group s free Ethics and Integrity Hotline. Failure to comply with this reporting obligation is itself a violation of this Policy. Suspected violations may be reported anonymously. In addition, it is Flint Group s policy to protect any employee from any form of adverse consequences or retaliation for reporting in good faith any suspected violation of this Policy. Employees must cooperate fully and openly with any investigation by the Company into alleged or suspected breaches of this Policy. Failure to cooperate or to provide truthful information during any investigation may render employees subject to disciplinary action, including dismissal. IX Training and Certification Flint Group is committed to training its employees in relation to anti-bribery and corruption issues, and the procedures and controls implemented in accordance with the requirements of this Policy. Employees are required to diligently and expeditiously undertake such training as the Company may provide or otherwise specify from time to time. Specific employees are also required to certify their compliance with this Policy on an annual basis through the Employee Representation Certificate (ERC) process. X Reporting Procedures XI Disciplinary Actions for Non-Compliance If a breach of this policy is suspected, each situation will be carefully and fully investigated. Where there is evidence of fraud, theft or bribery/corruption, we will take action to maintain our standards of integrity, regardless of the level or seniority of the person(s) concerned. The severity of the disciplinary measures will vary depending on the circumstances and the evidence in each case. Discipline can range from receiving a formal warning letter and/or being required to attend additional training on anti-corruption compliance, to termination of employment. Keep in mind that any internal disciplinary measures are in addition to any criminal or civil penalties imposed by law enforcement agencies. Violations of applicable anti-corruption rules can result in substantial criminal and civil penalties for individual employees. In many countries, the criminal penalties may include lengthy prison 6 F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y

sentences. XII Responsibilities for Implementing this Policy The Board of Flint Group is committed to ensuring that all the Company s activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct. The Board is responsible for establishing this Policy within Flint Group supported by an appropriate corporate culture led by the Board which prohibits bribery and corruption involving Flint Group employees or any third parties acting on behalf of the Company. The Chief Executive Officer, supported by the Senior VP Integrity and Compliance and the General Counsel, has responsibility for implementing this Policy in accordance with the requirements of the Board. The Executive Management Team (EMT) is responsible for ensuring that the Board s compliance commitment is clearly understood and reinforced across all the Company s businesses, divisions and functions, and that the requirements of this Policy are diligently and expeditiously followed by all employees within their respective businesses, divisions or functions. To this end, Integrity and Compliance will work with the President or Functional Head of each division, region or function within Flint Group to ensure that personnel are appropriately trained on their obligations pursuant to this policy. - XIV Monitoring and Audits The Company s General Counsel and the Senior VP Integrity and Compliance will monitor the effectiveness and review the implementation of this Anti-Bribery and Corruption Policy, and will report to Flint Group s Board of Directors on its adequacy and effectiveness. Any improvements identified by the Board of Directors will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to identify any potential red flags in the business operations and provide assurance that the controls are effective in countering bribery and corruption. These regular audits will include reviewing: general compliance with policies and procedures, general ledger accounts, cash disbursements, payments to third-party intermediaries and compliance with Flint Group s anti-corruption training and certification requirements. Employees and those who are working for or on behalf of Flint Group are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Senior VP Integrity and Compliance. Working with Integrity and Compliance pursuant to the Flint Group s Third Party Due Diligence Policy, the management teams of each division, region or function are responsible for ensuring that: (1) all Flint Group employees, and all third parties acting on behalf of Flint Group, are made aware of this Policy; (2) appropriate due diligence is undertaken in relation to the appointment of all third-party agents, distributors, suppliers and service providers; (3) appropriate anti-bribery and corruption contractual provisions are incorporated in the arrangements with such third parties; and (4) the activities of such third parties are monitored to ensure their compliance with the terms of this Policy. It is the responsibility of each Flint Group employee to ensure compliance with the terms of this Policy in the carrying out of his or her duties and responsibilities. XIII Revisions and Supplements This Policy may be periodically revised in response to changes in the Company s business, evolving best practices and the expectations of enforcement authorities. The Senior VP Integrity and Compliance is responsible for coordinating the updating of this Policy as needed. Employees and third parties must pay attention to revisions to this manual, related policies and procedures, and applicable guidelines. F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y 7

Appendix 1 Examples of conduct prohibited under this Anti-Bribery and Corruption Policy include ( Not an exhaustive list): - Offering, promising, giving, paying or authorising, directly or indirectly, any bribe, facilitation payment or kickback to or for the benefit of any person (whether in private or public office) in order to obtain any improper business advantage or other advantage for Flint Group, yourself or any person connected to you. - Becoming involved with government officials who ask for money/gifts for personal gain in exchange for using their official position in favour of the bribing party. - Soliciting, accepting or receiving (whether for Flint Group s benefit, your own benefit or the benefit of any person connected to you) any bribe, facilitation payment or kickback from any person (whether in private or public office) in return for any improper business or other advantage. - Using contracts or consulting agreements to channel improper payments through agents or other intermediaries to third parties (whether private or public). - Using illegal, unethical or improper means (including bribes, favours, blackmail, financial payments, inducements, secret commissions or other rewards) to influence the actions of others (whether in private or public office). - Acting as an intermediary for any third party (private or public) in the solicitation, acceptance, receipt, offering, promising, giving, paying or authorising of any bribe, facilitation payment or kickback or otherwise in the use of illegal, unethical and improper means to influence the actions of others (whether in private or public office). - Giving excessive financial support in the form of sponsorships of sports teams and individual sportspersons watch out especially where the team or individual is connected to a customer or potential customer. - Solicitations from officials of the Tax Authority for payments above those that the Company concludes it owes under local law. - Request to pay money or provide a gift of some kind to secure or process faster a licence/certificate for personal benefit of individual in government or tax person. - Lavish entertainment practices outside the Company policy on Gifts and Entertainment. - Provision or receipt of inappropriate entertainment practices with customers, agents, distributors, suppliers, etc. - Visa fast tracking unofficial agencies being corrupt and requiring payments for securing such visas. The agencies used must be official and recognised as authorised to perform these services. - Payments/gifts to customs authorities and/ or agents to process imports/exports. - Payment of a fee/gift to get products unloaded at customers premises - Business trips paid for, partners expenses paid, forced charity donations/ tips from Flint Group as a supplier. - Tax/VAT avoidance exploitation for personal or company gain. - Financial accounting to enhance team and/or individual bonus payments or company profit. - Customs/export tariff code manipulation for personal or business gain. - Relationship management with local authorities e.g. giving gifts or money to a local mayor or government official in order to build a strong relationship in order to secure his/her help when/if something goes wrong. - Waste disposal classification for personal or company gain e.g. what is hazardous/non-hazardous. - Using personal data for business/ personal gain e.g. selling or giving protected data to third parties. - Payments/excessive gifts to press room staff to favour our ink or avoid nonperformance of our ink. (Modest gifts such as cakes, biscuits, etc. are permitted.) - Bribing/attempting to bribe airport officials to get in/out of a country due to missing documents etc. (Where personal safety is at risk see travel guidelines and emergency numbers to seek advice.) - Conflict of interest e.g. transportation company appointed for personal gain or connection with friends, relatives etc. - Offer or receipt of cash in the form of a kickback, loan, fee or reward. - Giving of gifts and hospitality, including payment of expenses, to secure an advantage in business transactions. - Giving of aid, donations, etc. designed to exert improper influence. - Uncompensated use of company services, facilities or property e.g. lending a company car and driver for a weekend to a customer s family. 8 F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y

Appendix 2 More Information on Key Legislation The US Foreign Corrupt Practices Act (1977) and the U.K. Bribery Act (2010) are two broad laws that prohibit bribery worldwide: - The Foreign Corrupt Practices Act is a US statute that prohibits the making of corrupt payments (e.g. bribes) directly or indirectly to foreign government officials in order to obtain or retain business. A corrupt payment may be cash, gifts, hospitality or any other benefit. This law is not limited to corrupt payments made in the US it can apply to conduct anywhere in the world. Nor is the law limited to the conduct of US citizens under certain circumstances, it can apply to non-us citizens acting in countries outside the US Translations of the statute are available at http://www.justice.gov/criminal/fraud/fcpa/statutes/ regulations.html. - The UK Bribery Act is a statute that prohibits the giving or receiving, whether directly or indirectly, of corrupt payments (e.g. bribes) to or from any individual (including, but not limited to, government officials) in exchange for improperly performing a relevant function or activity, including any activity connected with a business and any act performed in the course of a person s employment. Further, a commercial organisation can also commit an offence under the Act for failing to prevent bribery. The statute is available at http://www.legislation.gov.uk /ukpga/2010/23/contents. These acts extend to actions that take place outside the US and UK; accordingly, a bribe is still an offence if it is committed overseas, and irrespective of whether the payment, offer or promise is legal under local law or accepted as part of local custom. Breaches of these statutes could result in the prosecution of Flint Group, its officers and/or its employees. In addition to these laws, there is a global trend for countries to enact and robustly enforce similar anti-bribery legislation. Flint Group respects all laws relevant to countering bribery and corruption in all the jurisdictions in which the Company operates, particularly laws that are directly relevant to specific or local business practices. It is the responsibility of every employee and business within Flint Group to ensure that its business practices in individual jurisdictions comply with all local requirements, and appropriate legal advice should be sought as necessary. F l i n t G r o u p : A n t i - B r i b a r y a n d C o r r u p t i o n P o l i c y 9

Flint Group Integrity Assurance Hotline Flint Group remains completely dedicated to fostering the highest level of ethics and integrity across our organisation. We expect all employees to do business in a respectful, honest and ethical manner. However, if you ever have a genuine concern of inappropriate business practice and feel unable to talk with your manager about it, EthicsPoint can help you report those concerns safely and reliably. Visit our web-based hotline portal to learn more. www.flintgrp.ethicspoint.com Your concerns will be heard. We take such information very seriously. www.flintgrp.com info@flintgrp.com linkedin.com/company/flint-group Published @flinteresting February 2015. Flint Group