Anti-Corruption Policy Statement

Introduction

This policy draws together Xtreme Fun Ltd.’s principles on anti-corruption.  The policy is designed to reduce the risk of Xtreme Fun Ltd. offering; soliciting or extorting bribes and therefore reduce the risk of it being subject to legal or regulatory sanctions and reputational damage.

Scope

The policy applies throughout the company to all staff and business activities. The following international laws from Global Infrastructure Anti-Corruption Centre & Transparency International, UK underpin this policy and it is subject to any more demanding local legal requirements.

Definitions

Corruption is the abuse of entrusted power for private financial or non-financial gain. It diverts resources from their proper use, distorts competition and creates gross inefficiencies in both the public and private sectors. Corruption can occur in the form of bribery, bribe solicitation or extortion.

Bribery is an offer or the receipt of any gift, loan, fee, reward or other advantage, whether directly or indirectly, to or from any person as an inducement to do something which is dishonest or illegal.

Bribe solicitation is the act of asking or enticing another to commit bribery.

Extortion is when bribe solicitation is accompanied by threats.

Facilitation payments are small payments made to expedite the performance of routine services to which the payer is entitled. For the purposes of this policy they are to be considered a form of bribery.

Policy

1. Xtreme Fun Ltd. prohibits bribery in any form – including the use of facilitation payments.
2. Xtreme Fun Ltd. must not make direct or indirect contributions to political parties or organizations or to individuals engaged in politics.
3. Xtreme Fun Ltd. must not allow charitable contributions and sponsorships to be used as a subterfuge for bribery.
4. Xtreme Fun Ltd. must not offer gifts, hospitality or expenses where such arrangements could improperly affect the outcome of a business transaction and are not reasonable expenditures made in good faith.
5. Staff must report any concerns they may have with respect to compliance with this policy. Xtreme Fun Ltd. must maintain processes to enable staff to raise such  concerns in confidence.
6. Xtreme Fun Ltd. must maintain processes to enable suppliers, customers and other third parties to raise concerns in confidence with respect to compliance with this policy.
7. Xtreme Fun Ltd. will not continue to use suppliers and other third parties where there is evidence that they have engaged in acts of bribery, as described in this policy, in connection with their dealings with the Group.

Assurance Check

Xtreme Fun Ltd. will undertake an annual review to ensure all related policies and procedures comply with this policy. The Board Members will review and ensure the investigation of any ‘Speaking Up’ or other reports raising concerns in relation to this policy.