Policy prohibiting bribery and other improper payments in the conduct of the PROJECX business operations

Corporate Governance

The PROJECX Group of Companies is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.K Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA) and other laws that prohibit improper payments to obtain a business advantage.

This document describes an overview of the PROJECX Policy prohibiting bribery and other improper payments in the conduct of the PROJECX business operations and the employee responsibilities for ensuring implementation of the Policy. Questions about the Policy or its applicability to particular circumstances should be directed to the Group CEO and or Managing Director or General Manager.

Policy Overview

PROJECX strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether they involve government officials or are wholly commercial. PROJECX believes that a bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and our company to possible criminal prosecution, reputational harm or other serious consequences.

Our Policy applies to everyone at PROJECX, including all officers, employees and agents or other intermediaries acting on behalf of the company. Each officer and employee of our Company has a personal responsibility and obligation to conduct our business activities ethically and in compliance with the law. Failure to do so may result in disciplinary action, up to and including dismissal.

Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of our companies business.

PROJECX has developed a comprehensive program for implementing this Policy, through appropriate guidance, training, investigation and oversight. The Group CEO has overall responsibility for the program, supported by the company Senior Management Team who are responsible for giving advice on the interpretation and application of this policy, supporting training and education, and responding to reported concerns.

Working with Agents, Sub Agents and Other Third Parties

PROJECX from time to time may engage the services of an agent, consultant or other intermediary to support its business activities, or may participate with business partners in a joint venture or other business structure. These relationships are important to PROJECX and provide valuable contributions in many areas of business, but can also pose compliance challenges and thus require appropriate measures to prevent bribery.

This Policy applies in all material respects to business conducted with or through an agent, consultant, joint venture or other business partner. Employees who manage, supervise and/or oversee the activities of third parties working with our company are responsible for ensuring that such persons or entities understand and fully comply with this Policy, through appropriate measures. Measures appropriate to a particular relationship or transaction may vary and should be identified pursuant to established guidelines, in consultation with the Group CEO.