Purpose, scope and responsibility

AMI’s Anti-Bribery and Corruption Policy establishes principles govern our conduct in order to conform to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and similar anti-corruption laws worldwide while confirming our commitment to conduct our business in an honest and ethical manner.

Zero-Tolerance Policy Statement

Asset Management International, Inc. has a zero-tolerance policy of bribery and corruption.

AMI will not seek to influence others, either directly or indirectly, by offering, paying or receiving bribes or kickbacks, or by any other means that is considered unethical, illegal or harmful to our reputation of irreproachable honesty and integrity. Employees and representatives of the Company are expected to decline any opportunity which would question or harm our ethical principles and reputation.

Bribery and corruption is contrary to AMI’s values; these acts we will never permit, they are illegal and can expose both the employee, contractors, vendors, and the Company to fines and penalties, including imprisonment and irreparable damage to our reputation.

Bribery and corruption defined

Bribery is “the giving, receiving, soliciting or promising of money, a gift or anything else of real or implied value as an inducement to do something that is dishonest, illegal or a breach of trust in order to secure business or a business advantage”. It is critical to understand that an act of corruption has occurred even supposing:

• A bribe was not successful.
• A person authorizes or provides direction for a bribe, but no bribe is ultimately offered or paid.

“Anything of value” includes, but is not limited to:

• Cash, cash equivalents (such as gift certificates/cards), stock, personal property and assumption or forgiveness of a debt.
• Any corporate travel, gifts, entertainment, and meals must be proportionate to the occasion and comply with the gift and entertainment-policy standards applicable to AMI’s policy and the policies of the client.
• Political contributions.
• Charitable contributions—if made to a charity at the direct request of a client, business partner, government official or, if such a contribution could be considered an indirect bribe made in order to obtain or retain business or to secure other improper business advantage.
• Employment offers or internship awards—offers to a client, business partner, government official (or their relatives) can present a risk of violating anti-bribery or anticorruption laws and regulations. A Managing Partner must be consulted prior to making such offers.

Core principles

• We will avoid appointing others to provide services for us or on our behalf who do not share these principles and who may harm our reputation.
• We will, always, act with integrity and avoid conflict of interest and any actions or situations that are inconsistent with our professional and legal obligations.
• We will set out our processes for avoiding bribery and keeping to and supporting our values.
• We will regularly review and update our program and processes as needed.
• We will make sure all members of the firm and our business partners know our principles.
• We will carry out our business fairly, honestly, openly and with integrity.
• We will not make bribes, nor will we condone the offering of bribes on our behalf.
• We will not accept bribes, nor will we agree to them being accepted on our behalf.

Procedures

AMI recognizes that any violation of anti-bribery and corruption laws could subject the Company and Members of the Firm to severe penalties including significant fines and imprisonment.

The Management Board requires the following procedures to be implemented and maintained:

• Strict compliance with this policy.
• Vigilance and reporting of any suspicion of bribery or corruption, immediately to a Managing Partner.
• Training to allow recognition of, and avoidance of, bribery. Training resource is compulsory for everyone at AMI. The provision of appropriate training is a key feature of our obligations under this Policy and is frequently monitored and audited.
• Thorough and rigorous investigation of any alleged bribery.
• Swift disciplinary action against anyone involved in bribery that may include termination.
• AMI’s employees, contractors, vendors, and business partners must be informed of this policy and must comply with this policy.

This Policy applies to all of AMI’s business dealings and transactions in all countries where we carry out business. It applies to all members of our business partners.

Reporting violations

Any act of bribery of corruption witnessed, or the suspicion of such, by must be immediately reported to a Managing Director.

Employees and representatives should seek clarification on any questions or concerns regarding activities under consideration or the interpretation of any law or policy. If you are offered a bribe from a person or entity doing business with or seeking to do business with AMI, report it immediately to a Managing Partner. If you are offered something of value and are uncertain whether you are allowed to accept it, refer to the Gift & Entertainment Policy and standards applicable to your location, or check with a Managing Director. Violations can be reported anonymously via AMI’s Ethics Email legal@4ami.com.

This Policy was created and approved by the Managing Partners on December 15, 2019 and is revalidated by the Management Board on an annual basis. The policy was last revalidated at the Management Board held on June 1, 2021.