Corporate Information Anti-Bribery & Corruption

Sterling Resources Ltd

Sterling Resources (UK) Ltd
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ANTI-BRIBERY & CORRUPTION STATEMENT

Introduction

Sterling Resources Ltd and its subsidiaries, including Sterling Resources (UK) Ltd, and Sterling Resources Netherlands B.V., (all collectively and individually herein referred to as Sterling Resources) recognise that bribery and corruption has a detrimental effect on communities wherever they occur. Bribery is a criminal offence in most countries in which Sterling Resources operates, and corrupt acts expose Sterling Resources and its employees to the risk of prosecution, fines and imprisonment, as well as endangering Sterling Resources’ reputation. It is Sterling Resources’ policy to comply with all anti-bribery and corruption laws of the UK, Canada or any nation in which we do business.

With the introduction of the UK Bribery Act 2010, Sterling Resources has taken steps to introduce “adequate procedures” which are rigorously applied and reviewed to ensure that we are fully compliant with the provisions of the Bribery Act.

It is Sterling Resources’ policy to maintain the highest level of ethical standards in the conduct of its business affairs and Sterling Resources has a zero tolerance of bribery and corruption. This policy has been adopted by the Board of Directors and is to be communicated to everyone involved in our business to ensure their commitment to it.

Scope

Sterling Resources’ zero tolerance of bribery and corruption applies to all officers, directors, employees, consultants, contractors and personnel as well as any agents, contractors, representatives or other parties acting on behalf of Sterling Resources, in any country where we may operate.

Sterling Resources expects our business partners, suppliers, contractors and agents to act with integrity and without thought or actions involving bribery and/or corruption and will, where appropriate, include clauses to this effect in relevant contracts.

The Statement

Sterling Resources prohibits:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement

to or from
any person or company, wherever they are situated and whether they are a public official or body or private person or company

by
any individual employee, agent or other person or body acting on Sterling Resources’ behalf

in order to
gain any commercial, contractual or regulatory advantage for Sterling Resources in a way which is unethical

or in order to
gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of Sterling Resources or of the person or body employing them or whom they represent.

Sterling Resources, in its ongoing efforts to keep its high ethical standards and with a view to upholding its position against any form of bribery, has implemented the following (the “Policies & Procedures”):

  • A clear Anti-Bribery and Corruption Policy with detailed guidance and procedures.
  • Training for all employees so that they can recognise and avoid the use of bribery by themselves and others.
  • Suitable channels of communication which encourage our employees to be vigilant and to report any suspicion of bribery and ensure sensitive information is treated appropriately.
  • Investigating procedures for instances of alleged bribery.
  • Procedures for taking firm and vigorous action against any individuals involved in bribery.

These policies and procedures augment the existing Sterling Resources group-wide policies and procedures relating to such matters, including the Code of Business Conduct and Ethics, which will continue to apply and require to be observed (but augmented by the Policies & Procedures).

Expectations of Sterling Resources Personnel

The prevention, detection and reporting of bribery and corruption is the responsibility of all employees and consultants throughout Sterling Resources. Suitable channels of communication by which employees, consultants or others can report confidentially any suspicion of bribery will be maintained, details of which can be found in Sterling Resources’ Anti-Bribery and Corruption Policy.

The Chief Executive Officer has lead responsibility for policy implementation within Sterling Resources and this policy is signed by the CEO to demonstrate the Board’s commitment.