Anti-Bribery and Corruption Policy of BRICS Bank SA

Valid from August 7, 2024

Policy Statement
BRICS Bank SA is committed to conducting its business with integrity and in compliance with all applicable laws and regulations. The Bank strictly prohibits bribery and corruption in all forms and is dedicated to maintaining the highest standards of ethical conduct.

Purpose
The purpose of this policy is to outline the Bank's approach to preventing bribery and corruption, ensuring compliance with legal requirements, and maintaining trust with stakeholders, including clients, shareholders, and regulators.

Scope
This policy applies to all employees, directors, officers, and third parties acting on behalf of BRICS Bank SA, regardless of their location or business unit. It covers all interactions with public officials, private sector entities, and non-profit organizations.

Definitions
- Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of an official or other person in charge of a public or legal duty.
- Corruption: Abuse of entrusted power for private gain.

Policy Requirements

1. Prohibition of Bribery and Corruption:
- BRICS Bank SA prohibits the offering, giving, receiving, or soliciting of bribes or any corrupt practices.
- Facilitation payments, also known as "grease payments," are strictly prohibited.

2. Gifts, Hospitality, and Expenses:
- All gifts and entertainment must comply with the Bank's Gifts and Entertainment Policy.
- Caution is advised when offering or accepting gifts or hospitality to avoid any appearance of impropriety.

3. Charitable Donations and Political Contributions:
- Charitable donations must align with the Bank's principles and not be used as a means to gain undue advantage.
- The Bank does not make political contributions to parties, organizations, or campaigns.

4. Third-Party Relationships:
- All third parties acting on behalf of the Bank must comply with this policy.
- Due diligence must be conducted before engaging third parties to ensure compliance with anti-bribery and corruption standards.

5. Training and Awareness:
- The Bank will provide regular training and communication to ensure all employees and associated persons understand and comply with this policy.

6. Reporting and Whistleblowing:
- Employees and associated persons must report any suspected or actual bribery or corruption incidents.
- The Bank provides a confidential whistleblowing line for reporting concerns.

Roles and Responsibilities
- The Board of Directors is responsible for ensuring an effective framework for managing anti-bribery and corruption compliance risks.
- The Compliance Officer is tasked with implementing and monitoring this policy.

Monitoring and Review
- The Bank will conduct regular audits and reviews to ensure the effectiveness of this policy.
- The policy will be reviewed annually or as required to ensure it remains relevant and effective.

This policy reflects BRICS Bank SA's commitment to ethical business practices and compliance with anti-bribery and corruption laws.