Anti-Bribery and Corruption Policy

Our Commitment to Integrity

At Snorkel, we are committed to doing business the right way—professionally, fairly, and with integrity. We have zero tolerance for bribery or corruption in any form, wherever we operate.

This policy reflects our obligations under the UK Bribery Act 2010 and applies to all employees, contractors, and third parties acting on behalf of Snorkel, both in the UK and internationally.

Why This Policy Matters

Bribery and corruption harm business, reputation, and public trust. The UK Bribery Act makes it a criminal offence to offer or accept a bribe, and both individuals and companies can face serious legal consequences—including imprisonment or unlimited fines.

Our policy helps everyone in our business understand what’s acceptable, what’s not, and how to act if something goes wrong.

What Is Bribery and Corruption?

• Bribery is offering, giving, receiving, or soliciting something of value (e.g., gifts, money, hospitality) to influence a decision or gain an unfair advantage.
• Corruption is the abuse of power or position for personal gain, and bribery is one of its forms.

Examples of bribery:

• Offering a gift to secure a contract.
• Accepting entertainment during an active bid or procurement process.
• Giving facilitation payments to speed up routine services, even if common in some countries.

Our Zero-Tolerance Approach

Snorkel prohibits:

• Any form of bribery or corrupt activity.
• Offering or accepting gifts, entertainment, or payments intended to influence decisions.
• Facilitation payments, kickbacks, or secret commissions.
• Undisclosed or unauthorised political donations.

We require:

• High ethical standards from all employees, partners, and representatives.
• Accurate record-keeping of all gifts and hospitality.
• Transparency in dealings with public officials and suppliers.

Gifts, Hospitality & Entertainment

We support appropriate business hospitality to build good relationships—but only when it’s:

• Reasonable and proportionate.
• Not offered to influence or reward improper behavior.
• Approved and properly recorded.

What’s Acceptable:

• Occasional small gifts (under £50).
• Modest business meals with a company host present.
• Promotional items or seasonal gestures.

What’s Not Acceptable:

• Cash or cash-equivalent gifts.
• Lavish or repeated hospitality.
• Gifts during bidding or contract negotiation.
• Anything that might damage Snorkel’s reputation.

For more detailed guidance, please see the Company Gifts and Hospitality Policy.

Who Must Follow This Policy

This policy applies to:

• All employees of Snorkel Europe Ltd.
• Contractors, consultants, agents, distributors, and any third party working on our behalf.
• Overseas offices and personnel (who must also follow local anti-bribery laws, such as the U.S. Foreign Corrupt Practices Act).

We expect our suppliers, partners, and business contacts to uphold similar standards.

What to Do if You’re Offered or Asked for a Bribe

If you are:

• Offered a bribe, politely decline and report it immediately.
• Asked to make a payment that seems suspicious, consult HR before proceeding.
• Unsure about a situation, speak with your line manager or HR.

If your safety is at risk, protect yourself first—then report the incident as soon as possible.

Raising Concerns: Whistleblowing

We encourage employees and partners to speak up if they see or suspect wrongdoing. Concerns can be raised confidentially under the Company Whistleblower Policy, and we guarantee:

• No retaliation or victimisation.
• Confidential handling wherever possible.
• Thorough investigation of every report.

Our Responsibilities

We are committed to:

• Conducting due diligence before working with third parties.
• Training employees on anti-bribery and ethical conduct.
• Maintaining clear financial records and internal controls.
• Reviewing and updating this policy regularly.

Consequences of Breach

Violating this policy may lead to:

• Disciplinary action (including dismissal).
• Contract termination (for third parties).
• Legal prosecution.

Oversight and Contact Information

This policy is overseen by:
Charles Brooks
Regional President EMEA & CFO
Responsible for implementation, training, and enforcement.

For questions or to report a concern, contact your line manager or HR, or refer to the Public Interest Disclosure (Whistleblowing) Policy.

Legal and Ethical Frameworks

This policy is aligned with:

• UK Bribery Act 2010
• U.S. Foreign Corrupt Practices Act
• OECD Anti-Bribery Convention
• UN Global Compact (Principle 10)
• Extractive Industries Transparency Initiative

Review and Updates

Snorkel will review this policy regularly to ensure it remains effective and compliant with legal requirements. Updates may be made without prior notice.

Related Policies

• Gifts and Corporate Hospitality Policy
• Public Interest Disclosure (Whistleblower) Policy
• Code of Conduct
• Travel, Subsistence and Entertainment Policy

This procedure is endorsed by the Company’s senior management and will be reviewed regularly. You are encouraged to raise genuine concerns without fear of reprisals.