Anti Bribery Policy

ANTI BRIBERY POLICY

No Clinton Enterprises (Overseas) Company, employee, agent or third party acting on its or their behalf shall, knowingly or in expectation:

Offer, promise or give a bribe to induce or reward another person to undertake or procure, the performance of an improper act;

Request, agree to receive or accept any bribe from another person by way of an inducement or a reward to undertake, or procure, the performance of an improper act or Unlawfully induce a foreign public official, in their official capacity, to obtain or retain business.