1. Hutchison Ports, its subsidiaries and controlled affiliates (collectively the Group), work with a wide range of business partners and suppliers of goods and services that meet its standards and quality requirements. Hutchison Ports strongly recommends that its business partners and suppliers adopt sound environmental performance, social well-being and sustainability management practices.
2. The Group is aware of the broader influence it has and therefore has adopted this Supplier Code of Conduct (the Code) from CK Hutchison as a guide to its business partners and suppliers, and to encourage compliance with the items in the Code so as to bring broader improvements in sustainability practices and performance for its business partners and suppliers and the communities the Group serves.
3. This Code should be read in conjunction with the Hutchison Ports Policy Circulars:
   • 9. Purchase of Goods and Services.
   • 60. Human Rights Policy.
   • 61. Modern Slavery and Human Trafficking Statement.
   or their subsequent updates.

4. The Group shall work with its business partners and suppliers which demonstrate adherence to best practices. It shall encourage business partners and suppliers to improve sustainability standards and practices, whilst respecting local traditions, cultures and norms.
5. The Group's business partners and suppliers are expected to disseminate and educate the requirements of this Code to their employees, agents, sub-contractors and suppliers, and hold them accountable for any non-conformance acts.
6. The Group shall also encourage and expect its business partners and suppliers to periodically assess themselves and their suppliers for conformance, and communicate their conformance status to the Group when requested. If non-conformance to this Code is detected, the Group shall attempt to work with them to correct the situation. The Group shall expect the business partner or supplier concerned to develop a corrective plan to bring its operations into Code conformance. If a business partner or supplier does not develop such a plan or fails to implement it, the Group may terminate the business relationship.
7. The content of this Code has been developed taking into account a number of international charters and conventions, including the United Nations Universal Declaration of Human Rights and the Fundamental Conventions of the International Labour Organization.

1. The Group shall encourage its business partners and suppliers to act in accordance with the highest standards of ethical conduct and professionalism.
2. In addition to these standards, the Group reiterates the importance of complying with all national and local laws and avoiding all forms of corruption and fraud. The Group's business partners and suppliers are required to implement anti-corruption policies and programmes, and to verify that such policies and programmes are complied with. It shall also encourage its business partners and suppliers to establish their own policies, practices and systems to ensure the promotion and dissemination of their own codes of conduct, where available, within their operations.

To safeguard the rights and dignity of employees, the Group shall encourage its business partners and suppliers to abide by the standards and conditions detailed below:

1. Ensure a fair and equitable workplace environment that is free from any form of harassment or discrimination based on, but not limited to, age, race or ethnic origin, disability, gender, nationality, marital status, sexual orientation, political convictions or union affiliation.
2. Provide a work environment that pays due consideration to safety and minimises any health hazards or harm to employees.
3. Prohibit the use of forced, prison, bonded and child labour, as well as any form of slavery or human trafficking, and remain in compliance with all applicable minimum age legislation.
4. Abide by any legislation governing minimum wage payments, and where none is available, ensure that salaries are commensurate with experience and industry standards.
5. Comply with regulation or legislation, where applicable, on maximum working hours.
6. Implement clear, uniformly applied disciplinary practices and grievance procedures that include provisions prohibiting corporal punishment, including mental, physical or verbal abuse.
7. Ensure that employees are provided with freedom of association and the right to collective bargaining. Where no such legislation on collective bargaining exists locally, appropriate channels should be made available for discussion and recourse on labour related issues.

The Group shall encourage its business partners and suppliers to consider the risks that climate change may pose to their operations, as well as to actively mitigate their impacts on the environment. The Group shall also reiterate to its business partners and suppliers the value that efficient use of resources and waste monitoring bring to the company. The Group shall invite its business partners and suppliers to emulate the standards, practices and principles set out below and in Hutchison Ports Policy Circular 48, Environmental Policy, or its subsequent updates.

1. Comply with all relevant local and national environmental legislation in such a way as to ensure the preservation of the environment.
2. Minimise the consumption of energy and carbon footprint from operations through the implementation of environmental policies and environmental management systems.
3. Encourage the use of environmentally friendly technology that can reduce energy consumption, minimise the need for business travel, and reduce reliance on resources such as paper.
4. Expand the use of environmentally friendly, recycled and/or sustainably forested products in operations.
5. Promote the recycling of waste while taking the necessary precautions, and ensure compliance with legislation on the handling or disposal of any hazardous materials in operations.

1. Hutchison Ports, its subsidiaries and controlled affiliates (collectively, the "Group") is committed to achieving and maintaining the highest standards of openness, probity and accountability.
   
   In line with this commitment, the Group expects and encourages employees of the Group and those who deal with the Group (e.g. customers, suppliers, creditors and debtors) to report to CK Hutchison Holdings Limited ("CKHH") any suspected impropriety, misconduct or malpractice within the Group.
2. This Policy aims to provide reporting channels and guidance on reporting possible improprieties in matters of financial reporting, internal control or other matters, and reassurance to whistleblowers of the protection that the Group will extend to them against unfair dismissal or victimisation for any genuine reports made under this Policy.

3. This Policy applies to all employees of the Group as well as third parties.
4. Whilst it is impossible to provide an exhaustive list of the activities that constitutes impropriety, misconduct or malpractice, this Policy is intended to cover serious concerns that could have an impact on the Group, which include but not limited to:
   1. criminal offences;
   2. breach of legal or regulatory requirements;
   3. miscarriage of justice;
   4. malpractice, impropriety or fraud in financial reporting, internal control or other financial matters of the Group;
   5. corruption, bribery, theft, fraud, the facilitation of tax evasion, financial crime or similar offences;
   6. breach of rules, policies or internal controls of the Group;
   7. endangerment of the health and safety of an individual;
   8. discrimination or harassment;
   9. damage caused to the environment;
   10. professional, ethical or other malpractices or wrongdoings;
   11. improper conduct or unethical behaviour likely to prejudice the standing of the Group; and
   12. deliberate concealment of any of the above.

5. In making a report, the reporting person or entity (the "Reporter") should exercise due care to ensure the accuracy of the information.
6. The Reporter making genuine and appropriate reports under this Policy is assured of protection against unfair dismissal, victimisation or unwarranted disciplinary action, even if the reports are subsequently proved to be incorrect or unsubstantiated.
   
   Harassment or victimisation of a genuine Reporter is treated as gross misconduct, which if proven, may result in dismissal.
   
   The topic of harassment stipulated in the CK Hutchison "Code of Conduct" and the corresponding glossary, and Hutchison Ports Policy Circular "34. Employment and Work Place Policy" or their subsequent updates shall be observed.

7. Each report will be treated as confidential. The identity of the Reporter will not be divulged save with such Reporter's consent or where:
   1. in the opinion of the Audit Committee of CKHH (the "Audit Committee"), it is material to the investigation or in the interest of CKHH to disclose the identity;
   2. the report is frivolous or is lodged in bad faith with malicious or mischievous intent or in abuse of this Policy;
   3. it is required to be disclosed in compliance with any applicable law or regulation, by any relevant regulatory authority including The Stock Exchange of Hong Kong Limited (the "Stock Exchange"), or by the order or directive of any court having jurisdiction over CKHH; and
   4. the report and the identity of the Reporter are already public knowledge.
   
   In order not to jeopardise the investigation and any follow-up actions, the Reporter is also required to keep confidential all information about and relating to the report, including the fact that he or she has filed a report, the nature of concerns, the identities of the parties involved and any other information that the Group has shared with the Reporter in the course of handling the report.

8. Making a Report
   
   
   1. Every report shall be made in person or in writing either by email to Report@ckh.com.hk (accessed by General Manager - Group Management Services of CKHH) or by post to:
      
      General Manager - Group Management Services
      CK Hutchison Holdings Limited
      48/F, Cheung Kong Center
      2 Queen's Road Central
      Hong Kong
      
      who shall report to the Chairman of the Audit Committee.
      
      The Chairman of the Audit Committee shall then determine the course of action to pursue, with power to delegate, with respect to the report.
   2. All written reports by post shall be sent in a sealed envelope clearly marked:
      
      "Strictly Private and Confidential - To be Opened by Addressee"
      
      to ensure confidentiality.
   3. If the General Manager - Group Management Services ("GMS") is being complained against or where a conflict of interest arises, perceived or otherwise, the report should be made in person or by post addressed to the Chairman of the Audit Committee at the same address.
   4. Each Reporter is required to provide details of improprieties (including relevant incident(s), behaviour, activity or activities, name(s), date(s), place(s) and any other relevant information) on the report.
   5. Details of the Reporter (including name, department/business unit, company, contact number, address or email address) are not required but are encouraged to be provided so as to facilitate the investigation, and such details will be kept in the strictest confidence.
   6. Reporters may also make their reports through the Group's other whistleblowing channels, and the management concerned should report to the General Manager of GMS according to the CK Hutchison Code of Conduct and CK Hutchison Anti-Fraud and Anti-Bribery Policy.
9. Investigation
   
   
   1. The format and length of an investigation will vary depending on the nature and particular circumstances of each report made.
      
      Where appropriate, the reports raised may:
      1. be investigated internally by the Audit Committee or, if delegated by the Audit Committee, the Company Secretary, the internal audit department, the human resources department or other departments of CKHH;
      2. be referred to the external auditor as instructed by the Audit Committee;
      3. be referred to the relevant public bodies or regulatory/law enforcement authorities as instructed by the Audit Committee; and/or
      4. form the subject of any other actions as the Audit Committee may determine in the best interest of the Group.
      
      If it is deemed appropriate and necessary to conduct internal enquiry/investigation into the relevant matter, efforts will be made to ensure it will not jeopardise any possible enquiry/investigation on the same matter by other relevant law enforcement authorities.
   2. The General Manager - GMS or the Chairman of the Audit Committee, where warranted, will respond to the Reporter, if contactable, as soon as practicable upon receipt of the report:
      1. acknowledging receipt of the report;
      2. advising the Reporter as to whether or not the matter will be investigated further and, as appropriate, the actions taken or being taken or the reasons for no investigation being made;
      3. where practicable, giving an estimate of the timeline for the investigation and final response; and
      4. indicating if any remedial or legal action is or is to be taken.

10. If a Reporter makes a false report maliciously, fraudulently, with an ulterior motive, or for personal gains, the Group reserves the right to decline to investigate or discontinue an investigation, and take appropriate actions against such Reporter (employees or third parties) to recover any cost, loss or damage as a result of such false report.
    
    Employees may also face disciplinary action, including dismissal where appropriate.

11. Records of all reported improprieties, misconducts and malpractices, including results of any investigations shall be kept by the relevant parties under paragraphs 8 and 9 for as long as necessary for the purpose of investigation and any possible follow up action.

12. This Policy shall be read in conjunction with and subject to any relevant laws, regulations, rules, directives or guidelines that the Stock Exchange or any other regulatory bodies may from time to time prescribe or issue on the matters governed by this Policy.
13. In the event that any procedures herein are inconsistent or in conflict with any relevant laws, regulations, rules, directives or guidelines as prescribed by the Stock Exchange or any other regulatory bodies or any part thereof, the latter shall prevail to the extent of such inconsistency or conflict.

1. Policy Statement
2. Prohibition on Improper Payments, Kickbacks and Other Forms of Bribery
3. Political and Charitable Contributions and Sponsorships
4. Facilitation Payments
5. Gifts and Hospitality ("Business Courtesies")
6. Procurement of Goods and Services by the Group and Other Business Partners
7. Third Party Representatives
8. Communication and Training
9. Books and Records
10. Reporting of Bribery, Fraud and Suspicious Activity
11. Review of this Policy

• Appendix 1: Fraud
• Appendix 2: Bribery

1.1 CK Hutchison Holdings Limited (the "Company", together with its subsidiaries and controlled affiliates, the "Group") is committed to upholding high standards of business integrity, honesty, fairness and transparency in all its business dealings, which is integral to the corporate culture of the Group. The Company strictly prohibits any form of fraud or bribery, and is committed to the prevention, deterrence, detection and investigation of all forms of fraud and bribery.

1.2 The Board is accountable to the implementation of the anti-fraud and bribery efforts of the Group which includes values, code of conduct, risk management, internal controls, communication and training, oversight and monitoring.

Directors and senior management of the Company are responsible for ensuring the effective implementation and in particular, the monitoring and investigation of any material fraudulent or bribery activities committed within the Group.

1.3 Fraud or bribery damages a company's reputation and undermines its relationship with its regulators, customers, business partners and competitors. It may lead to criminal prosecution of or regulatory action against a company and/or its employees, resulting in the imposition of criminal or civil penalties, including fines and imprisonment, and could damage a company's business.

Definition of fraud and some examples of fraudulent behaviour that may impact the Group are set out in Appendix 1 to this Policy.

1.4 This Policy applies to the Group, and to all directors, officers and employees of the Group (which for these purposes includes temporary and contract staff) (the "Employees"), as well as its Third Party Representatives (as further described in paragraph 7 below).

The Company encourages its business partners, including suppliers, to abide by this Policy, where applicable.

1.5 All Employees must maintain objectivity and avoid conflict of interest and subordination of judgment in the performance of their duties and responsibilities for the Group. They must disclose their interests in which a conflict may arise.

Please refer to the CK Hutchison Code of Conduct (Conflict of Interest).

1.6 All Employees are required to adhere to this Policy, as well as any additional requirements set by their employing company or by local law (which may be stricter than those set out in this Policy), the breach of which may lead to disciplinary action that might ultimately result in termination of employment and/or personal civil or criminal sanctions, or where appropriate, may also be referred to regulatory/law enforcement authorities.

1.7 This Policy sets out the minimum standards of conduct to which all Employees are required to adhere. The Policy should be read in conjunction with the CK Hutchison Code of Conduct.

1.8 Questions in relation to this Policy should be directed to the General Manager - Group Human Resources, or to the senior member of management designated by the local management of an Employee's employing company (or if no such person is designated, to the Head of Human Resources of their employing company).

2.1 Guidance on what could constitute "bribery" is contained in Appendix 2 to this Policy.

2.2 Employees are strictly prohibited (whether acting in their own capacity or on behalf of the Group) from:

1. offering, promising, giving or authorising, directly or indirectly, any bribe or kickback to or for the benefit of any person (whether in private or public office) in order to obtain any improper business or other improper advantage for the Group;
2. soliciting, accepting or receiving (whether for the benefit of the Group, their own benefit or that of their family, friends, associates or acquaintances) any bribe or kickback from any person (whether in private or public office) in return for providing any improper business or other improper advantage in relation to the business of the Group;
3. otherwise using illegal or improper means (including bribes, favours, blackmail, financial payments, inducements, secret commissions or other rewards) to influence the actions of others; or
4. acting as an intermediary for a third party in the solicitation, acceptance, payment or offer of a bribe or kickback.

2.3 In addition to complying strictly with the provisions in this Policy, Employees must exercise common sense and judgment in assessing whether any arrangement could be perceived to be corrupt, illegal or otherwise inappropriate.

3.1 It is the general policy of the Group not to make any form of donation to political associations or individual politicians. Employees must not use any funds or assets of the Group for contributions to any political party or candidate for public office.

In addition, no Employee may make any political contribution as a representative of the Group or create the impression that he or she is acting as a representative of the Group.

If any requests are made for political contributions by the Group, such requests should be referred, via the Group Corporate Affairs Department, to the Group Co-Managing Directors for consideration.

Please also refer to the CK Hutchison Code of Conduct (Political Contributions) and the CK Hutchison Corporate Communications Policy (Contribution to Politicians / Political Associations).

3.2 Charitable donations and sponsorships may in some circumstances constitute a disguised form of bribery. Therefore such activities should strictly follow the provisions set out in the CK Hutchison Corporate Communications Policy (Contribution to Charitable Organisation).

4.1 Facilitation payments (i.e. unofficial payments demanded in return for speeding up or securing the performance of routine government actions, such as obtaining visas, permits or licences) are prohibited.

5.1 Business gifts and hospitality are customary courtesies designed to build goodwill among business partners. In some cultures they play an important role in business relationships. However, a problem may arise when such courtesies compromise, or appear to compromise, the ability to make objective and fair business decisions.

Offering or receiving any gift, gratuity or hospitality that might be perceived to unfairly influence a business relationship should be avoided. The following guidelines apply at all times.

5.2 Business Courtesies must comply with the following principles:

1. they must be reasonable and not excessive;
2. they must be of modest value, both in isolation and when considered in the context of other gifts and hospitality offered;
3. they must be appropriate and consistent with reasonable business practice;
4. they must be provided with the intent only to build or maintain a business relationship or offer normal courtesy, rather than to influence the recipient's objectivity in making a specific business decision;
5. they should never be offered in return for financial or personal gain or favour; and
6. they must be permissible under all applicable laws, rules and regulations. When dealing with a public official, the official's country will often have laws imposing limits on the level of hospitality and gifts which can be accepted, and those laws must be strictly adhered to.
   
   When dealing with the private sector, gifts or hospitality should not exceed any limits imposed by the recipient's organisation.

5.3 Employees should use good judgment; "everyone else does it" is not sufficient justification.

Consider whether public disclosure of the Business Courtesy would cause embarrassment to the Group or the recipient; if so it should not be provided or accepted.

In determining whether a specific Business Courtesy lies within the bounds of acceptable business practice, Employees are encouraged to discuss the issue with their supervisor.

5.4 Each Group company is to have a procedure in place whereby Business Courtesies outside the normal course of business are documented and recorded, whenever accepted, given or rejected.

The record must expressly state the nature, purpose, value (if known) and date of the Business Courtesy and also details of the giver/receiver of the Business Courtesy. Such records must be preserved.

5.5 Each company within the Group is to set a pre-approved maximum limit for giving, and receiving, of gifts (including gift cards and gift certificates or vouchers), above which prior written approval must be sought from the Division Managing Director.

The pre-approved maximum limit for receiving or giving gifts at the Company level shall not exceed US$200 equivalent.

Whilst the pre-approved maximum limit for other companies within the Group will be determined in accordance with local professional and industry standards and may vary from country to country, such maximum limit for receiving or giving gifts shall not exceed US$200 equivalent.

In determining whether to approve gifts of a value higher than the pre-approved maximum, the Division Managing Director shall follow the principles set out in paragraphs 5.2 and 5.3 above.

6.1 The Group is committed to dealing with its customers and suppliers in a fair, honest and professional manner, while seeking best value for the business.

Potential suppliers are treated on an equal basis and no unmerited favouritism is to be shown in the procurement of goods and services.

The Group conducts its procurement practices in a fair and transparent manner and Employees must act with due care and diligence when evaluating prospective contractors and suppliers.

6.2 The Group will not deal with contractors and suppliers and other potential business partners known to be paying bribes and/or engaging in corrupt or fraudulent activities.

Appropriate levels of diligence are to be conducted by adequately skilled persons in the selection and renewal of new or existing contractors and suppliers and other business partners (such as a joint venture partner) commensurate with the bribery and/or fraud risk associated with a particular relationship.

6.3 The Group works with suppliers and business partners that demonstrate adherence to the best practices. Proper measures will be taken should these suppliers/business partners are found to be in breach of laws and regulations.

Please also refer to the CK Hutchison Supplier Code of Conduct for more details.

7.1 Legislation in some countries imposes criminal liability for a company's failure to prevent bribery or fraud by anyone providing services for or on behalf of the company.

The Group is committed to promoting anti-fraud and anti-bribery practices amongst any third party representatives it engages ("Third Party Representatives").

Third Party Representatives could include amongst others, advisers, agents, introducers and finders, consultants and political lobbyists.

The prohibitions in this Policy apply to Third Party Representatives engaged to represent the interests of the Group, a breach of which could result in termination of their engagement.

7.2 The approval of the Company is required in accordance with the CK Hutchison Policy on Appointment of Third Party Representatives before the appointment of any Third Party Representative.

7.3 To minimise the risk of Third Party Representatives engaging in inappropriate conduct, Group companies should:

1. always act with due care and diligence in selecting Third Party Representatives and in monitoring their activities;
2. ensure that Third Party Representatives are aware of and respect the CK Hutchison Anti-Fraud and Anti-Bribery Policy;
3. ensure that all fees and expenses paid to Third Party Representatives represent appropriate and justifiable remuneration, which is commercially reasonable under the circumstances, for legitimate services rendered by the Third Party Representative; and
4. keep accurate financial records of all payments.

8.1 Each Group company is to ensure that Employees are informed about and understand this Policy, including applicable local procedures and requirements, and that there is a clear escalation procedure for reporting actual or suspected breaches of this Policy and suspicious activity.

Each Group company is to make this Policy available to all Employees (whether in hard copy or online) and to provide briefings to new Employees thereon.

At a minimum, key Employees are to receive regular training relating to fraud and bribery risks faced by their organisation, as well as compliance with laws, regulations and standards of conduct which are relevant for their field of business.

8.2 It is every Employee's responsibility to counter fraud and bribery.

8.3 It is the responsibility of every manager to communicate this Policy to Employees.

Managers should ensure that all Employees reporting to them, and external parties within their area of responsibility working on behalf of their respective companies, understand and comply with the prohibitions in this Policy.

8.4 No Employee will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes even if such refusal may result in the Group losing business.

9.1 Each Group company should establish a robust financial and accounting control system, including adequate segregation of duties, authorisation controls and logging of entries or changes to ensure the accuracy and completeness of its books of account, as well as to prevent or detect any irregularities.

Such system is subject to regular review and audit.

9.2 Accurate records of all company transactions and (where required under paragraph 5.4) Business Courtesies must be kept.

All receipts and expenditures must be supported by documents that describe them accurately and properly. The falsification of any books, records or accounts of any company within the Group is prohibited.

9.3 Employees must not pay for Business Courtesies personally as a means of evading the requirements of this Policy.

10.1 If an Employee becomes aware of any actual or suspected breach of this Policy, he/she must report such incidents in accordance with the reporting and escalation procedures established by his/her employing company.

See also the CK Hutchison Whistleblowing Policy which provides a mechanism for Employees and those who deal with the Group to raise concerns on any suspected impropriety, misconduct or malpractice through confidential reporting channels.

10.2 As further set out in the CK Hutchison Code of Conduct (Reporting of Illegal or Unethical Behaviour), the timely reporting of actual or suspected breaches of this Policy lies with the finance manager having responsibility for the operation in which the incident occurs and ultimately lies with the Finance Director of the relevant Division, who is to report actual or suspected incidents of bribery, theft, fraud or similar offences to the Group Finance Director if the amount involved is greater than the de minimis amounts as agreed from time to time between the Group Finance Director and the Managing Director or Finance Director of the relevant Division.

All such matters must also be notified to the General Manager - Group Management Services ("GMS") for independent review and reporting to the Audit Committee.

10.3 Notification for cases above the de minimis amounts should be made by phone or confidential email or fax as soon as the Division management becomes aware of the incident, and in any event within one working day.

Reasonable liaison should then be maintained with the Group Finance Director and/or the GMS, as applicable, in order to ensure they are kept fully apprised of material developments in the case and able to offer forensic or other assistance as appropriate.

10.4 To facilitate the formal risk review and assessment by the Group, all business units should keep a register recording both suspected and actual incidents regardless of the amounts involved, and report the relevant statistics to Group Finance Director on a quarterly basis.

In addition, all the relevant information related to such cases should be made readily available for independent review and follow up by the GMS who then should report to the Audit Committee accordingly.

10.5 Employees are actively encouraged to report any concerns regarding fraud and bribery. Procedures are in place to ensure that such complaints are logged, investigated and appropriate action is taken.

Complaints are to be treated confidentially to the extent possible, and Employees raising legitimate concerns in good faith are to be protected; retaliation of any kind against any Employee for making good faith reports about actual or suspected violation of this Policy is not permitted.

10.6 Employees must cooperate fully and openly with any investigation into alleged or suspected corrupt or fraudulent activity or breach of this Policy.

Failure to cooperate or to provide truthful information may also lead to the Employee being subject to disciplinary action, up to and including dismissal.

11.1 The Audit Committee is responsible for the periodic review of this Policy to ensure its relevance and effectiveness, and shall make recommendation on any changes as may be required to the Board for approval.

This Policy is posted on the website of the Company.

1. The term "fraud" commonly encompasses deceptive conduct with the intention of making some form of financial or personal gain, or causing another person to suffer a loss, in each case, whether for the intended benefit of the Group or to its detriment.
   
   It includes, but is not limited to, deception, bribery, forgery, extortion, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts, and collusion.
2. Examples of general types of fraudulent behaviour that may impact the Group include but not limited to:
   1. obtaining financial advantage or any other benefit by false representation, deception or abuse of authority granted by virtue of official position or duty;
   2. unauthorised trading activities involving conflict of interest and/or gaining of personal interests;
   3. improper use of business information not released to the public and/or commercially sensitive information;
   4. theft, unauthorised use and/or disposal of Group assets or resources;
   5. false accounting and/or misleading disclosures;
   6. false declaration of work performed or misstatement of materials used in projects; and
   7. false payroll, false invoicing or false expense claims.
3. There is no set monetary threshold that defines a fraud. It is not necessary for the fraud to be successful to be viewed as a fraud.
4. The anti-fraud laws in the United Kingdom can also apply to companies wherever incorporated. Breach of these laws, including failure by a company to prevent fraudulent actions by any person for or on its behalf, can lead to severe penalties for companies and/or individuals.

1. Bribery involves giving or offering to give any advantage, directly or indirectly, to a public servant (i.e. officers, members and employees of public bodies) or any employee of a company or other person connected with a business, as an inducement or reward for or otherwise on account of such person's conduct in relation to the affairs of their employer or principal.
   
   It also involves soliciting or accepting bribes.
2. Bribery usually occurs where a person offers advantages to another as an inducement or reward for the recipient's improper performance of duties (usually to win or retain business or advantages), or where the recipient abuses his authority or position for personal gain.
   
   Bribery can also take place where the offer or payment is made by or through a third party.
3. Bribes and kickbacks can consist of anything of value (i.e. an "advantage"), including:
   • gifts, excessive entertainment and hospitality, sponsored travel and accommodation;
   • cash payments, whether by or to employees or business partners such as agents, finders, introducers or consultants;
   • other favours provided by or to public officials, suppliers or customers, such as engaging a company owned by a member of a public official or customer's family;
   • free use of a company's services, facilities or property; and
   • loans, loan guarantees or other extensions of credit on preferential terms, or other intangible forms of preferential treatment.
4. A list setting out examples of "Red Flags" which may be indicative of bribery is available from Group Legal Department for reference.
   
   If Employees spot any of the "Red Flags" in their dealings with a person/entity with whom the Group does or proposes to do business that arouse suspicion of bribery, they should report the matter in accordance with the reporting and escalation procedures established by their employing company.
5. Some countries, for example, the United Kingdom and the United States, have enacted anti-bribery laws which apply to the actions of citizens and domestic companies even if the activity takes place outside the United Kingdom or the United States.
   
   The anti-bribery laws in the United Kingdom can also apply to companies wherever incorporated which carry on a business or a part of a business in any part of the United Kingdom.
   
   Breach of these laws can lead to severe penalties for companies and individuals.