Anti Bribery Policy

Policy statement

It is Aimil policy to comply with all applicable anti-bribery laws, and all applicable local laws where Aimil operates, and to accurately reflect all transactions on Aimil’s books and records. It is also Aimil’s policy to require those agents, consultants and business partners who work on Aimil’s behalf before Government Officials to comply with these same laws and practices.

What it means

Aimil requires that:

•  Its employees not engage in acts or omissions that offer, authorize or give a bribe to a Government Official, or create the impression that a bribe has been offered, authorized or given
• Its employees take affirmative steps to prevent those doing business directly or indirectly before a Government Official on Aimil’s behalf from engaging in bribery
• Its employees adhere to Aimil’s mandatory due diligence, internal approval, financial reporting, and document retention requirements in the six key areas listed below and as fully set out under the topic “Anti-Bribery” on Aimil’s Legal Center
• Its employees scrutinize activities of certain acquisition targets and joint venture partners to identify and address potential bribery issues
• Its employees promptly report to Aimil any suspected violations by Aimil employees or others doing business before a Government Official on Aimil’s behalf and
• Its auditing function audit Aimil’s businesses as appropriate for potential bribery activities and risks

Key Areas
In addition to those obligations set forth above, Aimil requires specific due diligence, internal legal and business approvals, financial reporting, and document retention requirements in six key areas:

1. Aimil sponsorship of any travel-related benefits for any Government Official
2. Gifts to, entertainment for, or charitable contributions on behalf of any Government Official
3. Use of consultants and sales agents who may interact with Government Officials on Aimil’s behalf
4. Facilitating or “grease” payments to any Government Official
5. Activities with certain business partners who may interact with Government Officials directly or indirectly on Aimil’s behalf
6. Political contributions to any Government Official, political party, candidate or political organization Aimil employees can access these Mandatory Operational Standards and related tools on the Aimil Legal Center Intranet site, under the topic “Anti-Bribery”

What to Avoid

• The direct or indirect provision of cash or anything of value to a Government Official to obtain an unfair business advantage or to obtain or retain business
• Authorizing or providing travel benefits, gifts, entertainment, or political contributions for the benefit of a Government Official without the required due diligence assessment and internal Aimil business and legal approvals
• Entering into a consultant or sales agent agreement that will result in contacts with Government Officials without conducting due diligence, obtaining the required internal business and legal approvals, retaining all due diligence for eight years, and accurately recording on Aimil's book and records all related payments
• Making any "grease" or facilitating payments without obtaining the required Aimil internal business and legal approvals
• Making any incomplete, false or inaccurate entries on Aimil's books and records