Bribery & Corruption Policy Statement

The Lloyd Fraser Group is fully committed to its social, environmental, and ethical responsibilities and believes that corporate responsibility starts with the care of our employees, their health and safety, the environment in which we operate, and our principles for ethical practice must be reflected across the business.

It is the policy of the Lloyd Fraser Group that each director, manager and employee, will abide by all elements of all applicable UK law and follow all standards and principles relating to anti-corruption wherever the Company may operate or have any other type of activity.

The Lloyd Fraser Group will not tolerate any breach of this policy and any complaints made against a director, manager or employee of the Company will be investigated rigorously and disciplinary action will be taken where appropriate - no form of bribery, including improper offers or payments either to or from Lloyd Fraser Group employees, will be tolerated.

All contacts that involve Lloyd Fraser Group employees with governments, government agencies or officials will be conducted according to this Policy statement to ensure compliance with any applicable anti-corruption laws.

Any consultants, advisors or other agencies appointed to either assist or represent the Lloyd Fraser Group will be made aware of this policy and required to comply with its terms.

The responsibility for ensuring that the Lloyd Fraser Group, its operating companies and its employees, comply with both this policy and anti-corruption law rests with the Divisional Board and the senior management team.