Anti-Bribery Policy

1. Prohibited Conduct

• Offering, promising, giving, accepting, or soliciting a bribe in any form
• Facilitating payments to expedite routine government actions
• Providing gifts, entertainment, or hospitality intended to improperly influence a decision
• Making political contributions on behalf of KGML without express Board approval
• Engaging third parties with the knowledge they will pay bribes

2. Applicable Law

Our anti-bribery compliance programme meets or exceeds the requirements of the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), UAE Federal Law No. 11 of 2016, the Uganda Anti-Corruption Act 2009, and equivalent legislation in all other jurisdictions.

3. Gifts and Hospitality

Gifts and hospitality must be proportionate, reasonable, and offered without any expectation of a business advantage. All gifts above threshold values must be recorded in our Gifts & Hospitality Register. Any gift to a government official requires prior written approval from the Compliance Officer.

4. Third Parties

We conduct due diligence on all agents and intermediaries. Third-party agreements include anti-bribery obligations and rights of audit. We will terminate relationships with third parties found to be engaged in bribery.

5. Reporting

All employees are required to report suspected bribery through our Whistleblower channel. Reports will be investigated promptly and confidentially. KGML prohibits retaliation against any person who reports a bribery concern in good faith.