Anti-Bribery and Corruption Statement: Company Principles
Introduction
Chesnara plc and its business units (the ‘Company’) are committed to operating an effective anti-bribery & corruption framework across its operations. We believe that maintaining integrity and transparency in all our business dealings is essential to delivering our products and services responsibly. Each of our business units applies dedicated policies and procedures that align with applicable anti-bribery and corruption laws and regulations within their respective jurisdictions. We commit to preventing bribery and corruption at all levels, actively work to reduce our exposure to such risks, and have a clear stance towards any form of bribery or corrupt practice.
Company Principles
To ensure that we meet our commitments relating to anti-bribery & corruption activities, we have created a number of principles which are applicable across the Company. In accordance with these Company Principles, Chesnara plc and each of its business units:
- Have an anti-bribery & corruption policy signed off by the appropriate board, which clearly defines prohibited conduct and is designed to ensure compliance with relevant anti-bribery and corruption laws and regulations of the respective jurisdiction.
- Have designated persons with clear responsibility and accountability for anti-bribery & corruption controls.
- Ensure that a clear audit trail is maintained of all suspicions raised, investigations and decisions taken in respect of financial crime, including bribery and corruption.
- Have processes in place to establish the Company’s expectations with, and oversee compliance of, third parties in respect of preventing, detecting and responding to bribery and corruption. Third party engagement is subject to due diligence and a structured approval process. Due diligence encompasses evaluation of necessity, retention, relevant expertise, integrity and the method of payment to ensure that all relationships are lawful and transparent. Oversight of third parties includes comprehensive risk assessments, periodic screenings and health checks to identify any indicators of financial crime risk.
- Foster a culture in which integrity, transparency, and ethical behaviour are embedded throughout the organisation, and improper conduct is actively discouraged.
- Maintain a register of gifts, entertainment, and hospitality above a locally determined materiality threshold, and prohibit:
- Gifts or hospitality where something is expected in return;
- Cash or cash-equivalent gifts;
- Entertainment of a sexual or inappropriate nature;
- Gifts to or from government officials, regardless of local customs.
- Ensure that all staff, including part time and contractors, are appropriately and regularly trained to meet their anti-bribery & corruption obligations.
- Maintain a secure and confidential process for employees and others to report suspicions or concerns related to financial crime, without fear of retaliation
- Monitor, at least annually, all anti-bribery & corruption controls.
- Carry out, at least annually, a risk assessment to identify the key anti-bribery & corruption risks and whether any internal or external changes have affected those risks.
- Report to the relevant board the results of the risk assessment and monitoring activities and the effectiveness of relevant controls.
- Where required, cooperate fully with relevant enforcement agencies.
These Company Principles are supported by our broader Fraud Risk Policy which sets out the group’s approach to fraud prevention, detection, and response, in line with regulatory expectations and industry best practice. This includes carrying out regular assessments to identify and evaluate fraud risks, whether arising from business partners, transactions, geographies, or sectors as well as monitoring the effectiveness of our fraud controls.
Governance and Board responsibilities
The Chesnara plc Board is responsible for approving and overseeing the operation of the Group Financial Crime Policy, which sets the Company Principles on preventing, detecting and responding to bribery and corruption risks across the group. Through its review and approval of the Financial Crime Policy, the Board review and approve the Anti-Bribery & Corruption Principles that apply across the Company on an annual basis.
Business Unit Boards oversee local policies and procedures designed in accordance with the Company Principles and relevant laws and regulations within the respective jurisdiction.
This Anti-Bribery and Corruption Statement was last reviewed in March 2026 and reflects the Company Principles last approved by the Chesnara plc Board in August 2025.
