ASHTON APPAREL (EPZ) LIMITED

P.O. BOX 43371-80102, MOMBASA, KENYA

TEL: +254 41 02004768/9

Anti-Bribery & Anti-Corruption Policy

Definition:
a) Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving,
accepting, or soliciting something of value or of an advantage so to induce or influence an
action or decision.
b) A bribe refers to any inducement, reward, or object/item of value offered to another
individual in order to gain commercial, contractual, regulatory, or personal advantage.
c) Bribery is not limited to the act of receiving a bribe but also offering it.
d) Bribery is illegal.

ASHTON APPAREL (EPZ) LTD and all its Employees shall not engage in any form of bribery,
whether it be directly (as described above), or through a third party (such as an agent or
distributor). Any employee of ASHTON APPAREL (EPZ) LTD shall not accept bribes in any
degree and if he/ she is uncertain about whether something is a bribe or a gift or act of
hospitality, they must seek further advice from the company’s compliance manager.

Purpose:
This anti-bribery policy exists to set out the responsibilities of ASHTON APPAREL (EPZ) LTD
and employees in regards to observing and upholding our zero-tolerance position on bribery and
corruption. It also exists to act as a source of information and guidance for those working for
ASHTON APPAREL (EPZ) LTD. It helps them recognize and deal with bribery and corruption
issues, as well as understands their responsibilities.

Our Commitment:

ASHTON APPAREL (EPZ) LTD is committed to conducting its operations in an ethical and
honest manner, and is committed to implementing and enforcing systems and policies that ensure
bribery is prevented.
ASHTON APPAREL (EPZ) LTD has zero-tolerance for bribery and corrupt activities. We are
committed to acting professionally, fairly, and with integrity in all activities and relationships,
whichever countries or wherever in the country we operate.
ASHTON APPAREL (EPZ) LTD is committed to uphold all laws relating to anti-bribery and
corruption in all the jurisdictions in which it operates.
ASHTON APPAREL (EPZ) LTD recognizes that bribery and corruption are punishable by law
up to and including imprisonment and a fine.
Any employee found guilty of such an offence will be subject to termination of employment
contract

Handling of Reported Violations: ASHTON APPAREL (EPZ) LTD’s Compliance Officer /

Compliance Head / HR department at Central Office will notify the person who submitted a
Policy prepared by: Sagar Datta Name of the Document: Anti-Corruption & Anti-Bribery Policy
Reviewed by: Mr. Abizer Lokhandawala Reviewed and Approved by: Mr. Mannan Kapasi
Approved date: 04 January 2022 Revision due date: When there is a change in Policy / Law
Page 1 of 3 Version: HR/Policy/027
 ASHTON APPAREL (EPZ) LIMITED
P.O. BOX 43371-80102, MOMBASA, KENYA
TEL: +254 41 02004768/9

complaint and acknowledge receipt of the reported violation of this policy or a suspected
violation. All reports will be promptly investigated and appropriate corrective action will be
taken if warranted by the investigation [Refer Code of Ethics]

No Retaliation: It is contrary to the values of ASHTON APPAREL (EPZ) LTD, for anyone to
retaliate against any board member, officer, and employee or volunteer who in good faith reports
a violation, or a suspected violation of law, or suspected fraud, or suspected violation of any
regulation governing the operations of any Unit of ASHTON APPAREL (EPZ) LTD. An
employee who retaliates against someone who has reported a violation of this policy in good
faith is subjected to disciplinary action up to and including termination of employment.

Responsibility:
It is the responsibility of every employee of ASHTON APPAREL (EPZ) LTD to ensure that
he/she reads, understands, and complies with the information contained within this policy or
other anti-bribery and corruption information given.

All employees and those under ASHTON APPAREL (EPZ) LTD employment under contract are
equally responsible for the prevention, detection, and reporting of bribery and other forms of
corruption. They are required to avoid any activities that could lead to, or imply, a breach of this
anti-bribery policy.

If an employee has reason to believe that an instance of bribery or corruption has occurred or
will occur in the future that breaches this policy, he /she must notify the Compliance manager.

ASHTON APPAREL (EPZ) LTD has the right to terminate a contractual relationship with an
employee if they breach this anti-bribery policy.

ASHTON APPAREL (EPZ) LTD’s anti-bribery and corruption policy and zero-tolerance
attitude will be clearly communicated to all suppliers, contractors, business partners, and any
third-parties at the outset of business relations, and as appropriate thereafter.
ASHTON APPAREL (EPZ) LTD will provide relevant anti-bribery and corruption training to
employees etc. where company feels their knowledge of how to comply with this policy needs to
be enhanced.

ASHTON APPAREL (EPZ) LTD’s Compliance Manager is responsible for monitoring the
effectiveness of this policy and will review the implementation of it on need basis. He/she will
assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures designed to prevent bribery and corruption are subject to
regular audits to ensure that they are effective in practice. Any need for improvement will be
Policy prepared by: Sagar Datta Name of the Document: Anti-Corruption & Anti-Bribery Policy
Reviewed by: Mr. Abizer Lokhandawala Reviewed and Approved by: Mr. Mannan Kapasi
Approved date: 04 January 2022 Revision due date: When there is a change in Policy / Law
Page 2 of 3 Version: HR/Policy/027
 ASHTON APPAREL (EPZ) LIMITED
P.O. BOX 43371-80102, MOMBASA, KENYA
TEL: +254 41 02004768/9

applied as soon as possible.

ASHTON APPAREL (EPZ) LTD’s employees are encouraged to offer their feedback on this
policy in case of any suggestions for how it may be improved.

Feedback of this nature should be addressed to the compliance manager.

This policy does not form part of an employee’s contract of employment and ASHTON
APPAREL (EPZ) LTD may amend it at any time so to improve its effectiveness at combatting
bribery and corruption.

Note: Bribes will take many forms, for example:

Money (or cash equivalent such as shares);
Unreasonable gifts, entertainment or hospitality;
Kickbacks;
Unwarranted rebates or excessive commissions (e.g. to sales agents or marketing agents);
Unwarranted allowances or expenses;

i. “Facilitation” payments/payments made to perform their normal job more quickly

and/or prioritize a particular customer;
ii. Political/charitable contributions;
iii. Uncompensated use of company services or facilities; or
iv. Anything else of value.

Policy prepared by: Sagar Datta Name of the Document: Anti-Corruption & Anti-Bribery Policy
Reviewed by: Mr. Abizer Lokhandawala Reviewed and Approved by: Mr. Mannan Kapasi
Approved date: 04 January 2022 Revision due date: When there is a change in Policy / Law
Page 3 of 3 Version: HR/Policy/027