Policy Statement

Anti-bribery and Corruption

1. It implements policies and procedures to minimise the risk that a bribe is made by an associated person on its behalf;

2. It implements policies and procedures to minimise the risk that it is used to facilitate the payment or receipt of a bribe or the proceeds of corruption;

3. It acts as a responsible member of the community in deterring, preventing and, where necessary, reporting Bribery and Corruption to the relevant authorities; and, Its employees at all levels abide by the highest standards of moral and ethical behaviour.

4. Ashton Group will comply with both the spirit and specific provisions of all relevant Anti-Bribery and Corruption laws, regulations and rules.



Objectives of the Anti-Bribery and Corruption Strategy

The objectives of the Ashton Group Anti-Bribery and Corruption Strategy are as follows:

1. Ashton Group minimises the risk that an associated person pays or receives a bribe for or on its behalf;

2. Ashton Group minimises the risk that it is used to facilitate the payment or receipt of a bribe or the proceeds of corruption;

3. Ashton Group will take and enforce a zero tolerance attitude to Bribery and Corruption, whether committed by external third parties, any member of staff, its clients or any combination of these parties colluding together.

4. Ashton Group will constantly measure, monitor and report on Bribery and Corruption risk to enable Senior Management to better understand that risk and to enable them to maintain the appropriate policies and procedures required.

5. Ashton Group will proactively apply industry best practice with regards to Bribery and Corruption prevention and liaise as appropriate and where necessary with any industry bodies.