Bribery and Corruption Policy

Lev Liverpool is committed to ensuring that all of its activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct.

The purpose of this policy is to set out Lev Liverpool position on bribery and corruption and provide guidance to employees on the prevention, detection and reporting of bribery and corruption.

The corporate conduct of Lev Liverpool is based on acting responsibly, honestly and with integrity and the Company does not engage in or tolerate any form of bribery and corruption.

Any Lev Liverpool employee/operative engaging in business practices which infringe legal or regulatory requirements or fall below the highest standards of ethical business conduct may be subject to disciplinary action which may lead to dismissal and may face personal criminal or civil liability.

This policy applies to Lev Liverpool and every employee/operative (which for these purposes also includes temporary or contract employees) and their connected persons.

Lev Liverpool does not engage in or tolerate any form of bribery or corruption. It is contrary to the Company’s policy for any employee or third party acting on behalf of Lev Liverpool to engage in any conduct which may constitute bribery or corruption.

Lev Liverpool prohibits employees/operatives (whether acting in their own capacity or on the Company’s behalf) from:

• Offering, promising, giving, paying or authorising, directly or indirectly, any bribe, facilitation payments or other benefits 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 the

Company or themselves or any of their connected persons.

• Soliciting, accepting or receiving (whether for the Company’s benefit, their own benefit or the benefit of any connected persons) any bribe, facilitation payments or other benefit from any person (whether in private or public office) in return for any improper business or other advantage.
• Otherwise 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 payments or other kickbacks or otherwise in the use of illegal, unethical and improper means to influence the actions of others (whether in private or public office).

All employees/operatives are required to comply with this policy.

A signed copy of the company’s statement is located on the general noticeboards, however can be supplied upon request.