Anti-Bribery/Anti-Corruption Policy

Native is committed to conducting its business with integrity, honesty, and transparency. We unequivocally oppose all forms of bribery and corruption, recognizing them as serious crimes that undermine trust, fairness, and the rule of law. This policy sets forth our principles and guidelines for preventing bribery and corruption in all aspects of our operations.

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1. Policy Statement

Native prohibits bribery and corruption in any form, whether direct or indirect, by or involving any employee, agent, contractor, supplier, or representative of the company. We will not tolerate any conduct that violates this principle, regardless of the circumstances or parties involved.

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2. Compliance with Laws and Regulations

We will comply with all applicable anti-bribery and anti-corruption laws and regulations in every jurisdiction where we operate, including the UK Bribery Act.

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3. Responsibility of Management

Senior management at Native is responsible for fostering a culture of integrity and compliance throughout the organization. They will ensure that adequate resources are allocated to prevent bribery and corruption and that appropriate policies and procedures are in place to mitigate risks.

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4. Prohibited Activities‍

a. Bribery: Native prohibits offering, giving, receiving, or soliciting any bribe, kickback, or improper payment, whether in cash, gifts, services, or any other form, to or from any individual, organization, or government entity.

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b. Facilitation Payments: Native strictly prohibits facilitation payments, which are small payments or gifts made to expedite routine government actions. Such payments are illegal and undermine our commitment to fairness and integrity.

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c. Conflicts of Interest: Employees, agents, and representatives of Native must avoid conflicts of interest that could compromise their judgment or impartiality. They must disclose any personal, financial, or professional interests that could influence their decision-making or actions.

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5. Due Diligence and Risk Assessment

We will conduct thorough due diligence on all business partners, suppliers, contractors, and other third parties to assess their integrity and compliance with anti-bribery and anti-corruption standards. We will also regularly assess and mitigate the risks of bribery and corruption in our operations and business relationships.

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6. Reporting and Whistleblowing

We encourage employees, suppliers, and other stakeholders to report any concerns or suspicions of bribery or corruption within our organization or supply chains. We will maintain confidential reporting mechanisms and ensure protection for whistleblowers against retaliation.

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7. Investigation and Enforcement

All reports of suspected bribery or corruption will be promptly and thoroughly investigated by the appropriate authorities within Native. If misconduct is substantiated, disciplinary action will be taken, up to and including termination of employment or contracts, and appropriate legal action may be pursued.

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8. Continuous Improvement

We are committed to continuous improvement in our anti-bribery and anti-corruption efforts. We will regularly review and update this policy to reflect changes in laws, regulations, and best practices and to address emerging risks and challenges.

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9. Communication

We will communicate our anti-bribery and anti-corruption policy to all employees, suppliers, and stakeholders and make it readily accessible to the public through our website. We will also communicate our commitment to integrity and ethical business practices in all our interactions and engagements.