Anti-Bribery & Corruption

Prohibited conduct

No person acting for Meridian BlueWater may offer, promise, give, request or accept anything of value intended to secure an improper advantage or influence a decision improperly.

Gifts, hospitality and third parties

Reasonable and transparent hospitality may be acceptable where lawful and never intended to influence improperly. Cash gifts and facilitation payments are prohibited. Third parties must not be used to do anything prohibited directly.

Controls

• Use accurate contracts, invoices and records
• Complete proportionate checks on higher-risk intermediaries
• Declare actual or potential conflicts
• Seek guidance where intent or propriety is unclear

Reporting

Suspected bribery or corruption must be reported promptly. Retaliation against a person raising a genuine concern is not accepted.

This document is reviewed periodically and may be updated to reflect legal, operational or regulatory developments.