This policy sets out AuHandel’s commitments and controls to:

• Prevent bribery and corruption in all forms.
• Manage gifts, hospitality, and conflicts of interest appropriately.
• Ensure third parties acting for AuHandel follow equivalent standards.
• Provide a safe channel for raising concerns.

This policy applies to:

• All AuHandel business activities and relationships.
• Interactions with public officials and private parties.
• Gifts, hospitality, sponsorships, charitable contributions, and any benefits provided or received in connection with AuHandel’s activities.
• All third parties acting for or on behalf of AuHandel (agents, consultants, introducers, intermediaries, and relevant service providers).

AuHandel commits to:

• Conduct business ethically and lawfully and prohibit bribery and corruption in any form.
• Maintain proportionate controls to identify and manage corruption risks in relationships and transactions.
• Require third parties and counterparties (where appropriate) to meet integrity expectations and cooperate with due diligence.
• Escalate, investigate, and take action on credible concerns without retaliation.

AuHandel strictly prohibits:

• Bribes: offering, promising, giving, requesting, or accepting anything of value to improperly influence any decision or secure an improper advantage.
• Kickbacks: any undisclosed or improper payment or benefit connected to awarding business or influencing outcomes.
• Facilitation payments: “small payments” to speed up routine actions (prohibited).
• Improper benefits: gifts, travel, hospitality, employment offers, or other advantages intended to influence decisions.
• False documentation: misrepresenting origin, taxes, fees, or compliance status; or creating/accepting fraudulent records.
• Indirect bribery: bribery conducted through third parties, introducers, consultants, agents, or intermediaries.

AuHandel permits only modest, infrequent, transparent gifts or hospitality that are:

• Lawful.
• Not intended to influence a business decision.
• Not cash or cash equivalents.
• Not offered/accepted during a sensitive decision period (e.g., onboarding, negotiation, risk review).
• Properly recorded where required.
• AuHandel prohibits cash gifts or equivalents (gift cards, vouchers with cash value).
• Lavish or excessive hospitality.
• Any benefit offered to secure improper advantage or to bypass controls.
• When in doubt, personnel must decline or seek approval from the Compliance Lead.

Interactions with public officials carry elevated risk. AuHandel will:

• Apply enhanced scrutiny to transactions or relationships involving public officials or high-risk government-facing points (e.g., customs, licensing, law enforcement).
• Prohibit any attempt to influence public officials improperly.
• Require escalation and documented approval for any exceptional circumstances.

AuHandel recognises third parties can increase corruption risk. Where AuHandel uses intermediaries, introducers, consultants, or agents, we will:

• Conduct risk-based due diligence on the third party.
• Understand the legitimate services provided.
• Require appropriate contractual commitments (including compliance with this policy).
• Prohibit success fees or commissions that are not transparent, documented, and commercially reasonable.
• Monitor performance and disengage if integrity concerns arise.
• AuHandel may refuse engagements involving unidentified, undisclosed, or unvetted intermediaries.

AuHandel requires personnel and relevant representatives to avoid situations where personal interests conflict with AuHandel’s interests or could be perceived as influencing decisions. Examples include:

• Undisclosed financial interests in counterparties.
• Family or close personal relationships that could influence decisions.
• Outside employment that creates conflicts.
• Conflicts (actual or potential) must be disclosed to management/Compliance Lead and managed appropriately.

AuHandel maintains appropriate records of:

• Approvals (where required).
• Third-party due diligence and contracts.
• Relevant transaction documentation and decision-making.
• Any reported concerns and investigation outcomes (consistent with confidentiality).

AuHandel provides periodic training to relevant personnel on:

• Bribery and corruption risks in commodities and cross-border trade.
• Gifts/hospitality rules and red flags.
• Intermediary risk and escalation procedures.

Concerns about bribery, corruption, fraud, or improper conduct may be reported via:

• Email:complaints@auhandel.com
• AuHandel treats reports discreetly.
• Prohibits retaliation for good-faith reporting.
• Investigates proportionately.
• Escalates credible allegations to senior management.

Breaches of this policy may result in:

• Refusal or termination of business relationships.
• Disciplinary action (for personnel/representatives).
• Reporting to authorities where required by law.

This policy is reviewed at least annually and updated as needed based on:

• Legal/regulatory changes.
• Risk context changes.
• Learnings from implementation and reported concerns.