Anti-Bribery Policy Statement

It is the policy of William Hackett Holdings together with its subsidiary companies (collectively referred to as "the
Companies"), to conduct our affairs in an ethical manner that satisfies our statutory and contractual obligations, and
wherever possible we meet and exceed the expectations of our employees, suppliers, customers, regulatory authorities and other stakeholders.

The directors and management of the Companies are committed to a business ethos based on adopting good practice and ethical dealings with all our stakeholders. The directors and management will provide the necessary leadership, policies, procedures, resources and guidance to enable implementation of this business ethos throughout the organisation.

The Companies have policies and procedures in place which require the directors, management, employees, suppliers
and contractors to comply with the following aims and objectives as regards anti-bribery:

We will carry on our business fairly, honestly and openly
We will conduct our business in accordance with our statutory obligations including the requirements of the Bribery
Act 2010 and any ancillary legislation
We will not make bribes so as to gain a business advantage nor will we condone the offering of bribes on our
behalf
We will not accept bribes to influence business nor will we agree to bribes being accepted on our behalf
We will avoid doing business with others who do not accept our values and who may harm our reputation
We will maintain processes, procedures and records that limit risk of direct or indirect bribery
As far as possible we shall ensure that all of our staff, suppliers, customers and other business partners are aware of our anti-bribery policy
We will ensure that all of our employees and suppliers are aware of our aspirations, and given the necessary
information, training and instruction to ensure that these objectives can be fulfilled
We will review our performance during audits carried out by senior management personnel and external
consultants and service providers
We will review this policy regularly and update it when necessary

This policy is an integral part of the Companies' management system; shall be made available to external parties; and
subject to review when necessary and appropriate.

Timothy J. Burgess

Managing Director

13 May 2020

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Anti-Bribery Policy Statement

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