Policy

ANTI-CORRUPTION & BRIBERY POLICY

Anti-Corruption and Bribery Policy;

Introduction & to whom this shall apply?

Corruption and bribery are illegal and unethical. They destabilize communities, undermine the rule of law, and pose serious threats to sustained economic progress and the healthy operation of markets. Failure to address the risk of corruption and bribery may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/ or individuals. We do not engage in corruption and we never pay bribes, regardless of local custom or practice. Newtech’s position on corruption is clear: the offer, payment, authorization, solicitation and acceptance of bribes and other improper advantages is unacceptable. This Anti-Corruption and Bribery Policy sets out Newtech’s approach to the prevention of bribery and other forms of corruption.

The policy applies to all employees, directors and officers, as well as contractors under Newtech’s direct supervision, working for a Newtech office or industrial asset directly or indirectly controlled or operated by Newtech worldwide. We assert our influence over joint ventures we don’t control or operate to encourage them to act in a manner consistent with our Values and Code.

Our Commitment;

We do not tolerate bribery of any kind, whether to a public official or a private individual. We never offer, provide or authorize bribes of any kind, including facilitation payments, either directly or indirectly, to a public official or a private individual. We never request or accept bribes of any kind, either directly or indirectly. A bribe may be monetary or non-monetary, tangible or intangible. A bribe may take the form of, or be facilitated through:

·         Payments of money.

·         Gifts or entertainment.

·         Discounts, loans and/or financing given on non-commercial terms.

·         Rebates or kickbacks in relation to services provided.

·         Overpayments to business partners.

·         Use of assets at a discount or free of charge

·         sponsorships, charitable contributions and community investments

·         Political contributions.

·         Employment or internships.

·         Information or assistance.

To manage our bribery and corruption risk, we implement a range of procedures and controls relating to dealings with public officials, gifts and entertainment, our business partners, sponsorships and donations, political contributions and record keeping. We remain alert to corruption and bribery red flags and report them to Compliance.