Anti-Bribery & Anti-Fraud Policy Date of Approval November 2020

3 Purpose The purpose of this policy is to set out the responsibilities of the Center in observing and upholding the Center’s position on fraud, bribery, and other corrupt business practices. [...] This policy is not meant to prohibit the following practices provided they are customary in a particular market, are proportionate, and are properly recorded; ● normal and appropriate hospitality; ● the giving of a ceremonial gift on a festival or at another special time subject to the limits imposed by the HR policy; and ● the use of any recognized fast-track process which is available to all on. [...] 6.1 Charitable Contributions Any charitable contributions made or offered on behalf of the Center must; ● not be related to, dependent on, or made to win or influence, a business deal or decision; ● be given directly to the relevant charity or cause and not to an individual; and ● be aligned to the Center’s gift acceptance policy. [...] ● Staff must declare and submit a written record of all hospitality or gifts accepted or offered to the Executive Director, which will be subject to the Executive Leadership Team review in line with the Center’s HR policy and as outlined in the Center’s HR policies and procedures manual. [...] ● Continuously communicate with staff about the Center’s values and the zero-tolerance stance on bribery and fraud 8 ● Assure prompt attention to any reports made to them, at the minimum they should report to the Director of Operations.