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Transactions Involving Government
Anti Bribery And Corruption
Officials & Political Contributions

In addition to ensuring our culture of ethics and compliance Our company takes a very hard-line stance with respect to
remains a priority, maintaining an unwavering focus on our our conduct and the way we carry out businesses with
zero tolerance for corruption policy in spite of the pandemic government officials. This is important to ensure that our
ranks equally important.
reputation as a trusted company is protected, and we remain
a leading company grounded in ethics and integrity.
Waltersmith understands that bribery and corruption is bad
for business and our anti-bribery and corruption (ABC)
internal procedure manual categorically states this and Thus, any form of monetary transaction inclusive of
prohibits any engagement and or conduct that appears to hospitalities and gifts, to government officials may be made
encourage bribery and corruption in whatever form. Our only in compliance with our ABC procedure. Prior to any
reputation and success as a company is built upon a such payment being made to a government official, the
foundation of integrity – a commitment to act within the
Legal Department must determine that such payment is in
highest ethical standards and to conduct business honestly
strict compliance with laid down rules as well as relevant
and legally.
local laws. Additionally, such payments must be accurately
Our ABC procedure is intentionally encompassing and wide recorded to reflect transparency. This guidance played a
in scope to include any person, organization or bodies doing huge role in 2020 as we collaborated with the government
business with the Company or any of its subsidiaries and and the health care sector to provide covid-19 palliatives.
employees. Our staff understand the need to be very familiar
with our ABC procedure and we have engagement sessions As part of our company policy, we adopt a position of
that incorporate training, and guidance.
neutrality with respect to politics and do not engage in any
contributions to parties or political campaigns.
We also have our terms and conditions for working with our
vendors which includes clear policies that prohibit unethical
conduct and the possibility of contract termination where
there is a breach of our policies.

In the year under review and as part of our procedure, our
Risk management and compliance department prepared an
annual report on the Company's ABC compliance program to
the Company's Audit Committee and the Board.

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