Effective date: 01 January 2026
Waymark Metals Limited (“Waymark Metals”, “we”, “us” or “our”) is committed to conducting its business with the highest standards of integrity, transparency and ethical conduct. This Anti-Bribery and Corruption Policy sets out our zero-tolerance approach to bribery and corruption and forms a core part of our governance framework.
This Policy applies to Waymark Metals Limited and all subsidiaries, affiliates and connected companies operating in the United Kingdom, European Union, United Arab Emirates, United States, Saint Kitts & Nevis, the British Virgin Islands, Sierra Leone, Liberia and Guinea (Conakry) (together, the “Waymark Group”).
This Policy must be read in conjunction with the Waymark Metals Code of Conduct, which underpins all behaviour and decision making across the Group.
1. Policy Statement and Standard of Compliance
Waymark Metals adopts the UK Bribery Act 2010 as its primary global standard, regardless of where it operates. Where local laws are stricter, those laws must also be complied with.
We have zero tolerance for bribery, corruption, facilitation payments or improper influence in any form, whether direct or indirect.
2. Scope and Application
This Policy applies to all:
- Directors, officers and employees
- Consultants, contractors and advisers
- Agents, intermediaries and representatives
- Joint venture partners and counterparties acting on our behalf
Compliance with this Policy is a condition of engagement with Waymark Metals.
3. What Constitutes Bribery and Corruption
Bribery includes offering, promising, giving, requesting or accepting any advantage intended to improperly influence a decision or secure an improper business advantage.
Corruption includes abuse of entrusted power for private gain, whether involving public officials or private parties.
This applies equally to:
- Cash and non-cash benefits
- Gifts, hospitality and entertainment
- Political or charitable contributions
- Indirect payments via third parties
4. Prohibited Conduct
You must not, directly or indirectly:
- Offer, give, request or accept a bribe or improper advantage
- Make facilitation payments of any kind
- Use third parties to circumvent this Policy
- Provide gifts or hospitality that could influence, or appear to influence, decision making
- Engage in improper dealings with public officials
Facilitation payments are strictly prohibited, even where they may be customary or tolerated locally.
5. Public Officials and High-Risk Jurisdictions
Special care must be taken when dealing with public officials, state-owned entities or regulators, particularly in higher-risk jurisdictions.
Any interaction with public officials must be:
- Lawful
- Transparent
- Properly documented
- Approved in accordance with internal procedures
6. Gifts, Hospitality and Expenses
Gifts and hospitality must be:
- Reasonable, proportionate and infrequent
- Clearly for legitimate business purposes
- Not intended to influence decision making
Lavish, excessive or inappropriate gifts or hospitality are prohibited. Cash or cash equivalents are never permitted.
7. Third Parties and Due Diligence
Waymark Metals conducts risk-based due diligence on third parties.
No third party may be engaged where bribery or corruption risks cannot be reasonably mitigated. All third parties must agree to comply with standards consistent with this Policy and the Code of Conduct.
8. Record Keeping and Controls
All financial records must be accurate, complete and transparent. Off-book accounts, false records or misleading entries are strictly prohibited.
Adequate internal controls must be maintained to prevent and detect bribery and corruption.
9. Whistleblowing and Reporting Concerns
Waymark Metals encourages the reporting of any suspected or actual bribery, corruption or unethical conduct.
Reports may be made confidentially and, where permitted by law, anonymously. Reports can be raised through management or via designated compliance channels.
No retaliation will be tolerated against anyone who raises a concern in good faith, even if the concern is ultimately unfounded.
10. Investigations and Cooperation
All reports will be taken seriously and investigated appropriately. Covered persons must cooperate fully with internal investigations and any lawful requests from regulators or authorities.
11. Consequences of Breach
Breaches of this Policy may result in:
- Disciplinary action, including termination of employment or engagement
- Termination of contracts or partnerships
- Referral to law enforcement or regulators
Waymark Metals reserves all rights to protect its legal and commercial interests.
12. Training and Awareness
Waymark Metals is committed to promoting awareness of anti-bribery and corruption risks. Training may be provided where appropriate, particularly for individuals operating in higher-risk roles or jurisdictions.
13. Responsibility and Oversight
Senior management is responsible for oversight and enforcement of this Policy. Ultimate accountability for compliance rests with the Board of Waymark Metals.
14. Review of Policy
This Policy will be reviewed periodically and updated to reflect changes in law, regulation or business practice.