Anti-Bribery and Anti-Corruption Policy

1. Policy Statement

xthAB Limited has a zero-tolerance approach to bribery and corruption. We are committed to acting ethically and with integrity in all our business dealings. This policy is adopted in compliance with the Bribery Act 2010.

2. Scope

This policy applies to all officers, employees, contractors, and agents of xthAB Limited, as well as any third party acting on our behalf. It covers all business dealings in every country in which we operate.

3. Prohibited Conduct

• Offering, promising, or giving a bribe (financial or otherwise)
• Requesting, agreeing to receive, or accepting a bribe
• Making facilitation payments to expedite routine government actions
• Making political donations or charitable contributions intended to influence business decisions

4. Gifts and Hospitality

Modest gifts and hospitality may be given or accepted where they are reasonable, proportionate, and made in good faith. All gifts above a de minimis threshold must be recorded in our gifts and hospitality register and approved by management.

5. Due Diligence

We conduct proportionate due diligence on business partners, suppliers, and carriers, particularly those in jurisdictions with a higher perceived risk of corruption (as assessed by Transparency International's Corruption Perceptions Index).

6. Reporting

Suspected violations should be reported to ethics@xthab.com. We operate a whistle-blowing procedure and will not tolerate retaliation against anyone who raises a concern in good faith.

7. Consequences

Any employee found to have violated this policy will face disciplinary action, up to and including dismissal. Violations may also result in criminal prosecution under the Bribery Act 2010.