ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

Bribery and corruption offences present a very serious risk for all businesses. These risks can lead to unlimited fines for companies, imprisonment of individuals and loss of reputation. The enforcement of bribery and corruption laws in many countries is increasingly stringent and also encompasses activities undertaken by a company through its employees or third parties acting on its behalf across various international jurisdictions.

PAC Districentre’s corporate conduct is based on acting responsibly, honestly, with integrity and the Company does not tolerate any form of bribery and corruption.

The Compliance Committee is responsible for establishing this policy within PAC Districentre, supported by an appropriate corporate culture which prohibits bribery and corruption involving either PAC Districentre employees or any third parties acting on behalf of the Company.

As part of this policy as well as Company’s Corporate Policy, our Employees are encouraged, without fear of retaliation, to raise a red flag if they observe any violation of Company policy, rule, regulation, etc. Any concerns raised are then thoroughly investigated and handled.

Compliance with this policy is mandatory for all PAC Districentre’s Employees and Vendors and same is regularly reviewed and audited to ensure its continuous suitability, effective and proportionate with regards to Company’s operations and the jurisdictions within which it operates.