An Act introduced in 2015 to make provision about slavery, servitude and forced or compulsory labour and about human trafficking. Devine Distillates Group embraces this act across all its business worldwide including provision for the protection of victims; to make provision for an Independent Anti-slavery Commissioner; and for connected purposes.

Devine Distillates Group is a privately owned business that has been guided in its business dealings by a strong belief in morals and business ethics. This belief lies behind our 4 Corporate Values of Be Professional, Be sincere, Be Sustainable and Think Long Term, each of which helps to support and drive our corporate behaviour.

Being Professional means ensuring integrity and transparency in all of our actions and behaviours. Because of that, we believe that any sort of bribery, corruption or improper payment of any kind is unacceptable in our business dealings anywhere in the world and is therefore not tolerated.

When conducting our business we will follow the 9 principles listed below.

1. We will conduct our business dealings in compliance with the laws of every country in which we operate or sell our products, regardless of what local practice might be.

2. We will never offer or give money, gifts, hospitality or other advantages to anyone we do business with, or to anyone associated with them, to get them to do something they shouldn’t do.

3. We will never offer or give money, gifts, hospitality or other advantages to any public official in order to try and get them to give us a business advantage.

4. We will never pay facilitation payments.

5. We will never ask or allow other people to do any of these things for us.

6. We will never accept money, gifts, hospitality or other advantages from anyone we do business with, or from anyone associated with them, to get us to do something we shouldn’t do.

7. We will only do business with other people or companies who commit to doing business without bribery and will immediately stop doing business with any people or companies who we have reasonable grounds to believe may be making or accepting bribes.

8. We have clear rules and guidance for all employees on giving and receiving gifts and hospitality. We do not allow our employees to give money, gifts, hospitality or other advantages to other people, or to receive these things from other people if they are intended to influence someone to act in an improper way.

9. We will never discipline or condone negative treatment of any employee who complies with this Policy, even if it means we lose money or business as a result. We will, however, give our fullest support to any employee who makes us aware of any breaches of this Policy.

We operate a zero-tolerance approach to bribery and any employee who does not comply with this Policy will be subject to the Company’s disciplinary procedures. Non-compliance with this Policy may constitute gross misconduct and result in

Version 1/2015 Devine Distillates Group anti-Corporate Anti Bribery Policy