Anti-Corruption Policy

Introduction

Plantations International wants to be the best in its industry, but not at any cost. It aims to provide a workplace where employees meet high business and personal standards and take pride in the company and in their work.

The company's core values are Accountable, Customer Focused and Team Driven. Its stated objective is a winning, inclusive culture that drives results.

Employees represent the company to customers and others. They must follow the Code of Business Conduct (COBC) and act with Respect, Integrity, Good judgement, Honesty and Trust: "the RIGHT Way".

This policy extends the COBC principle of complying with anti-corruption laws. It applies to all employees and to anyone doing business with the company, including agents, representatives, consultants, independent contractors and anyone acting on its behalf.

Questions should be directed to the local Legal Officer or the Ethics and Compliance Office.

Purpose of the Anti-Corruption Policy

The policy sets out acceptable and unacceptable behaviour so that the company complies with the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all domestic and foreign laws that prohibit improper payments, gifts or inducements. This covers dealings with public and private officials, customers and suppliers.

Helpful Definitions

• Bribe: anything of value offered to affect a person's actions or decisions in order to gain or keep a business advantage. "Anything of value" includes cash, entertainment and other gifts or courtesies.
• Corruption: the misuse of public office or power for private gain, or the misuse of private power in business.
• Facilitation payments: small payments to government officials to speed up routine actions. Non-discretionary government actions count as facilitation payments.
• Kickbacks: the return of a sum already paid or due, as a reward for awarding or furthering business.

What Does "Anti-Corruption" Mean to You?

Corruption occurs in many activities, usually for financial or personal gain. Bribes may take the form of money, privileges, valuable items, advantages or promises. Typically two parties are involved and both benefit.

Examples include cash offered or received as a kickback, loan, fee or reward, and aid, donations or votes given to exert improper influence.

The main high-risk areas are:

• Gifts, entertainment and hospitality
• Facilitation payments
• Procurement
• Political, community and charitable contributions

1. Gifts, Entertainment and Hospitality

Gifts, entertainment and hospitality are acceptable if they are reasonable, proportionate, given in good faith, documented and compliant with company policies. The relevant policies are the COBC (conflicts of interest), the Customer Entertainment Policy and the Corporate Hospitality Guidelines, which list what is usually acceptable and what is never acceptable.

Examples include gifts, meals, tokens of appreciation and invitations to events. They must stay within reasonable value and frequency.

Before accepting or offering anything, ask yourself:

• What is the intent: relationship-building or something else?
• How would it look in a newspaper?
• Would the situation be a double standard if it were reversed?

If You Are Unsure

Ask your manager, the Legal Department or the Ethics and Compliance Office. If your manager is involved in the situation, seek a higher-level manager.

Government Officials and Political Contributions

As a general rule, no gifts or hospitality may be given to or received from government or public officials, their close family or their business associates. A modest gift may be given where appropriate and lawful, but only with the prior written approval of the Legal Department.

Political contributions are governed by the COBC section "Engaging in Government and Political Activities". They are allowed only as permitted by law and with advance approval from the senior public affairs officer and legal counsel.

2. Facilitation Payments

Facilitation payments are not allowed. If you are unsure whether a payment qualifies, contact the local Legal Officer or the Ethics and Compliance Office.

3. Procurement Process

Employees must follow company processes and internal controls when selecting suppliers. Selection must never be based on a gift, hospitality or payment.

Formal tenders require documentation of internal controls. In the public sector, tenders may be mandated by law to keep competition for public money open, fair and free from corruption.

The principles of a tender are:

• No party may gain an unfair advantage through prior closed-door negotiations.
• Bidding is open to all qualified bidders.
• Sealed bids are open to scrutiny.
• Awards are based on price and quality.

4. Political, Community and Charitable Contributions

Political contributions from company funds require authorisation. Permitted contributions must be approved in advance by the senior public affairs officer and legal counsel. The company is not permitted to make political contributions in France, Belgium or Great Britain.

Community and charity contributions must be made in good faith and must comply with the COBC, this policy and all related company policies and procedures.

Books, Records and Internal Control Requirements

Expenses must never be hidden or deliberately misclassified. Inaccurate record-keeping is common in serious bribery cases, and anti-corruption laws generally require detailed, accurate records of transactions, including cash and bank accounts.

Each business unit must maintain effective internal controls and transaction monitoring, including approval controls for travel and entertainment expenses. Employees are responsible for knowing and following these controls.

You Are Responsible

Violations are treated as serious and may lead to disciplinary action, up to and including termination, consistent with local law.

Bribery is a criminal offence. Individuals are accountable whether they pay a bribe or authorise, assist or conspire in one. Penalties may include imprisonment, probation, community service and significant fines. The company will not pay these fines.

Questions or How to Raise a Concern

Report questions or suspected violations immediately to any of the following:

• Your manager
• Your local Legal Department
• The Ethics and Compliance Office, directly through Karen Gallows, Chief Compliance and Risk Officer, on +852 5808 3775

Policy Ownership and Scope

The Legal Department owns this policy. Questions should go to the local Legal Department or the Ethics and Compliance Office.

The policy applies to all full-time and part-time employees of the company and its subsidiaries, plus agents, affiliates, contractors, sub-contractors, introducers and non-company-owned franchise agents. Exceptions apply where otherwise specified or required by federal, national, country, state or local law, or by a collective bargaining agreement.

For clarification, call +852 5808 3775 or use the contact details page.

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