OASST Ltd is committed to upholding the highest standards of honesty and integrity in all its business dealings, no matter where they take place.

This policy on bribery and corruption applies to all employees of OASST Ltd. We also expect our business partners and service providers, regardless of their location or role, to act with integrity and refrain from any actions involving bribery or corruption.

OASST Ltd’s policy requires all employees to:

1. Not offer or make any kind of bribe or unorthodox inducement to anyone.
2. Not solicit opportunities by offering bribes or other unorthodox inducements to potential customers.
3. Not accept any bribes or unorthodox inducements that have not been authorised by OASST Ltd in the normal course of business.
4. Refuse any bribe or unorthodox inducement clearly and firmly, and report any such offers to ensure transparency.
5. Not make facilitation payments to secure or expedite the performance of routine actions for which they are entitled.
6. Report any breaches of this policy. Employees can confidentially report concerns to any Board member or through our confidential Ethics Hotline without fear of reprisal. All reports will be taken seriously, and no one will face discrimination for reporting concerns in good faith.

Any violation of this policy may result in disciplinary action, up to and including dismissal.

Note: Reasonable, proportionate hospitality or promotional expenditure made in good faith is a recognised part of business. The Bribery Act 2010 does not penalise such activities; however, excessive hospitality or expenditures could indicate an attempt to influence or reward improper performance. Factors such as the nature of the hospitality or lack of clear business connection may raise red flags. (“Guidance of the Director of the Serious Fraud Squad and the Director of Public Prosecutions”).

Revised September 2024