Anti-Bribery and Anti-Corruption Policy

1.Introduction

Evea Limited (“EVEA”) is committed to conducting its business activities with integrity, transparency, and in compliance with all applicable laws and regulations. Bribery and corruption undermine trust, distort competition, and can have serious legal and reputational consequences. This Anti-Bribery & Anti-Corruption Policy outlines the standards and procedures that employees, representatives, and business partners of EVEA must adhere to in order to prevent bribery and corruption in any form.

2.Policy Statement

EVEA is committed to conducting all aspects of its business in an honest and ethical manner. EVEA will not tolerate any form of bribery, corruption, or unethical behavior, whether direct or indirect, and regardless of the form it takes. EVEA will comply with all applicable anti-bribery and anti-corruption laws and regulations in all jurisdictions in which it operates, including but not limited to the Nigeria Anti-Corruption Act, the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any other relevant local laws.

3.Scope

This policy applies to all employees, officers, directors, contractors, agents, consultants, and any other individuals or entities acting on behalf of Evea Limited, regardless of location.

4.Prohibited Conduct

• Bribery: EVEA prohibits the offering, giving, receiving, or soliciting of any bribe, whether cash or non-cash, to or from any person or organization, including government officials, customers, suppliers, or any other third party, in order to gain a business advantage or to influence decision-making improperly.
• Kickbacks: EVEA prohibits the offering, giving, receiving, or soliciting of kickbacks or any other form of improper payment, rebate, or compensation in exchange for favorable treatment or business opportunities.
• Facilitation payments: EVEA prohibits the payment of facilitation payments or "grease payments" to expedite or secure routine governmental actions or services.
• Political contributions: EVEA prohibits the making of any political contributions, donations, or payments that are intended, directly or indirectly, to influence any government official or political party for improper purposes.

5.Gifts, Entertainment, and Hospitality

• Acceptance of gifts: EVEA employees must exercise caution when offered gifts, entertainment, or hospitality by customers, suppliers, or other business partners. Gifts, entertainment, or hospitality must be of nominal value, appropriate, and in compliance with applicable laws and regulations.
• Giving of gifts: EVEA employees must not offer or give gifts, entertainment, or hospitality that could be perceived as intended to influence business decisions or gain an improper advantage.

6.Record-Keeping and Transparency

Accurate and transparent record-keeping is essential to prevent bribery and corruption. Employees must accurately record all transactions and expenditures related to business activities in accordance with company policies and applicable accounting standards.

7.Reporting and Compliance

• Reporting violations: EVEA employees, officers, directors, and third parties acting on behalf of EVEA are encouraged to report any suspected violations of this Policy to the Compliance Department or through the company's confidential reporting channels.
• Investigations: Evea will investigate all reports of alleged bribery or corruption promptly and impartially. Employees are expected to cooperate fully with any investigation conducted by the company.
• Compliance training: EVEA will provide regular training to all employees and relevant third parties on their obligations under this Policy and applicable anti-bribery and anti-corruption laws and regulations.

8.Consequences of Non-Compliance

Violation of this Policy may result in disciplinary action, up to and including termination of employment or the contractual relationship, as well as legal action where applicable. EVEA may also report violations to relevant authorities, which could result in civil or criminal penalties for both individuals and the company.

9.Review and Revision

This Policy will be reviewed periodically to ensure its effectiveness and compliance with applicable laws and regulations. Amendments or revisions to this Policy may be made as necessary by the Compliance Department with the approval of the Board of Directors, and employees will be informed of any updates.

By adhering to this policy, Evea affirms its commitment to conducting business with honesty, integrity, and transparency.

10.Acknowledgment

All employees, officers, directors, and third parties acting on behalf of EVEA are required to acknowledge receipt and understanding of this Policy and to certify their compliance with its provisions on an annual basis.