How we behave in every business dealing.

It is the policy of Numata Business IT (Numata) to conduct business in an honest and ethical manner. As part of that, Numata takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

Numata will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad, and including in South Africa the Prevention and Combating of Corrupt Activities Act, 2004 (PCCAA).

This policy applies to all individuals working for or on behalf of Numata at all levels and grades, whether permanent, fixed-term or temporary and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of Numata (collectively referred to as Workers in this policy).

In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of Numata's business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.

A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act.

• Giving or offering a bribe.
• Receiving or requesting a bribe.
• Bribing a foreign public official.
• Numata may also be liable under the Act if it fails to prevent bribery by an associated person, including but not limited to Workers, for Numata's benefit.

This policy does not prohibit normal and appropriate gifts and hospitality, given and received, to or from Third Parties unless otherwise specifically stated. We have internal policies and procedures which guide Workers on what is regarded as normal and appropriate in terms of financial limits, subject to the Overriding Principles below, namely that any gift or hospitality:

• Must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.
• Must comply with local law in all relevant countries.
• Must be given in the name of the organisation, not in an individual's name.
• Must not include cash or a cash equivalent.
• Must be appropriate in the circumstances.
• Must be of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
• Must be given openly, not secretly.
• In the case of gifts, must not be offered to, or accepted from, government officials or representatives, politicians or political parties without the prior approval of Numata's Anti-Bribery Compliance Partner, the Compliance Officer for Legal Practice (COLP) or the Compliance Officer for Finance and Administration (COFA).
• Numata appreciates that the practice of giving business gifts varies between countries and regions, and that what is normal and acceptable in one region may not be in another. The test is whether, in all the circumstances, the gift or hospitality is reasonable and justifiable in the UK, South Africa or any other relevant country. The intention behind the gift should always be considered.

It is not acceptable for any Worker, or someone on their behalf, to:

• Give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that they or Numata will improperly be given a business advantage, or as a reward for a business advantage already improperly given.
• Give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure.
• Accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage.
• Accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by Numata in return.
• Threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy.
• Engage in any activity that might lead to a breach of this policy.

We do not make, and will not accept, facilitation payments or kickbacks of any kind, such as small unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

Numata only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and that accord with Numata's internal policies and procedures.

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers must avoid any activity that might lead to, or suggest, a breach of this policy.

Workers must notify Numata as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in future, or if they are offered a bribe, are asked to make one, suspect that this may happen in future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with non-employee Workers if they breach this policy.

If any Third Party is aware of activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with Numata's Anti-Bribery Compliance Office, Etienne Topham, at compliance@numata.co.

Training on this policy is provided for all Workers, and our zero-tolerance approach to bribery and corruption is communicated, where appropriate, to clients, suppliers, contractors and business partners.

Numata monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are subject to regular review to provide assurance that they are effective in countering any risk of bribery and corruption. All Workers are aware that they are responsible for the success of this policy and should use it to disclose any suspected danger or wrongdoing.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

The Organisation has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

The Organisation is committed to transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (UK) and the Prevention and Combating of Trafficking in Persons Act, 2013 (Act No. 7 of 2013) (RSA). We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for the Organisation or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee's contract of employment and the Organisation may amend it at any time. Queries about this policy should be directed to the Compliance Officer.

The Organisation has overall responsibility for this policy with senior management, and managers have day-to-day responsibility for ensuring compliance with our legal and ethical obligations. The Compliance Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and on the issue of modern slavery in supply chains.

You must read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

• Notify your manager or the Compliance Officer as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in future.
• Raise concerns about any issue or suspicion of modern slavery in any part of our business or in the supply chain of any supplier tier at the earliest possible stage, through your manager, the Compliance Officer or our Whistleblowing Policy.
• If you are unsure whether a particular act, the treatment of workers, or their working conditions within any tier of our supply chains constitutes a form of modern slavery, raise it with your manager or the Compliance Officer.
• We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
• No one will suffer detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. Report any such treatment to the Compliance Officer immediately; if the matter is not remedied and you are an employee, raise it formally using the Grievance Procedure held by the HR department.

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, is provided as necessary. Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. The Organisation may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.