Anti-corruption & bribery

Urrum is committed to conducting business lawfully, ethically and with integrity in every jurisdiction in which it operates or supports client activities. Corruption and bribery undermine fair competition, distort markets, weaken institutions and expose businesses and individuals to significant legal, financial and reputational harm.

Urrum does not tolerate bribery or corruption in any form. We do not offer, promise, give, request, authorise or accept bribes or any other improper advantage, whether directly or indirectly, regardless of local custom, perceived market practice or commercial pressure.

This Anti-Corruption and Bribery Policy sets out Urrum’s principles, minimum requirements and control expectations for preventing bribery and corruption across its business activities, including procurement support, sourcing activities, commercial engagement, contract support, supplier interactions and dealings involving public or private counterparties.

Who this policy applies to?

This Policy applies to:

• all Urrum directors, officers and employees;
• consultants, secondees and temporary personnel acting on behalf of Urrum;
• contractors and subcontractors working under Urrum’s direction or control;
• third parties engaged by Urrum where they act for or represent Urrum in business dealings, sourcing, supplier engagement, logistics coordination, project support or contract-related activities.

Where Urrum participates in joint engagements, consortium arrangements, partnerships or subcontracting structures that it does not fully control, it will seek to promote standards consistent with this Policy.

Our commitment

Urrum does not tolerate bribery of any kind, whether involving a public official or a private individual.

Urrum will never:

• offer, promise, provide or authorise a bribe or improper advantage;
• request, solicit or accept a bribe or improper advantage;
• use intermediaries, consultants, business partners, agents or suppliers to do anything that URRUM would be prohibited from doing directly;
• disguise improper payments through false invoices, inflated fees, sham services, rebates, commissions, sponsorships, gifts, travel, hospitality or any other mechanism.

A bribe may be monetary or non-monetary, direct or indirect, tangible or intangible. It may take the form of, or be facilitated through:

• payments of cash or cash equivalents;
• gifts, meals, travel or entertainment;
• discounts, credits, loans or financing on non-commercial terms;
• rebates, kickbacks or secret commissions;
• excessive or unjustified service fees;
• overpayments to suppliers, agents or intermediaries;
• free use of assets, equipment, services or facilities;
• sponsorships, donations or community support intended to secure influence;
• employment offers, internships or preferential treatment;
• confidential information, assistance or other advantages.

All Urrum personnel are expected to remain alert to red flags and to escalate concerns promptly.

Public officials

Dealings with public officials present heightened corruption risk and require increased caution.

For the purposes of this Policy, Urrum applies enhanced scrutiny to any interaction involving:

• government ministries, departments or agencies;
• customs, port, border or licensing authorities;
• state-owned or state-controlled entities;
• regulators, inspectors or tax authorities;
• public procurement bodies;
• political office holders, candidates or party representatives;
• employees or representatives of public international organisations.

Urrum personnel must not offer, provide or authorise any payment, gift, travel, hospitality or other advantage to a public official unless it is lawful, transparent, reasonable, properly approved in advance and clearly not intended to influence any decision or obtain any improper benefit.

Facilitation payments

Urrum prohibits facilitation payments.

Facilitation payments are unofficial payments made to secure or expedite routine governmental actions, such as permits, clearances, processing, inspections, customs release, utility connection or document issuance.

If any person acting for Urrum is asked to make such a payment, they must refuse and report the request immediately to management or Compliance.

Payments made under duress

Urrum places the safety and wellbeing of its personnel first.

If an individual reasonably believes that there is an immediate threat to health, liberty or physical safety, they should take reasonable steps to protect themselves. In exceptional circumstances, this may involve making a payment under duress.

Any such incident must be reported as soon as safely possible, with full details recorded so that Urrum can assess the circumstances, document the matter and implement any necessary follow-up action.

Gifts, hospitality, travel and entertainment

The giving or receiving of gifts, hospitality, travel or entertainment can create actual, perceived or potential corruption risk if not properly controlled.

Urrum permits only those gifts, hospitality, travel or entertainment that are:

• modest, reasonable and proportionate;
• infrequent and made in good faith;
• transparent and accurately recorded;
• for a legitimate business purpose;
• lawful under applicable rules and local law;
• not intended to influence, reward or induce improper conduct.

Urrum personnel must not provide or accept gifts, hospitality, travel or entertainment that:

• are intended to influence a decision, award or outcome;
• create a sense of obligation or expectation of favourable treatment;
• could reasonably be perceived as a bribe;
• are excessive, lavish or unusual in context;
• involve cash or cash equivalents, including gift cards redeemable for cash;
• are offered during a live tender, bid, negotiation, evaluation or approval process without explicit prior approval.

Higher-risk situations, especially those involving public officials, procurement decisions, contract awards or dispute resolution, must be subject to enhanced review and approval.

Sponsorships, donations and community contributions

Urrum will never use sponsorships, charitable contributions, community investments or other external support as a means to conceal a bribe or gain an improper commercial advantage.

Any such contribution must:

• serve a legitimate and documented purpose;
• be proportionate and transparent;
• be subject to appropriate due diligence and approval;
• be recorded accurately in Urrum’s books and records;
• not be linked, explicitly or implicitly, to any business award, permit, approval or preferential treatment.

Political contributions

Urrum does not use political contributions to secure business advantage.

No political contribution, whether financial or in-kind, may be made in Urrum’s name or using Urrum resources unless expressly authorised by senior management and permitted by law. As a general rule, Urrum personnel must not make political contributions on behalf of Urrum.

Business partners and third parties

Third parties can create significant bribery and corruption exposure, particularly where they interact with suppliers, clients, intermediaries, public authorities or logistics stakeholders on Urrum’s behalf.

Urrum expects its business partners to operate to ethical and lawful standards consistent with this Policy.

Before engaging higher-risk third parties, Urrum will apply a risk-based review, which may include:

• identity and ownership checks;
• reputation screening;
• sanctions and integrity screening where appropriate;
• review of qualifications, commercial rationale and scope of work;
• assessment of relationships with public officials;
• review of compensation structure and payment terms;
• evaluation of country, sector and transaction risk.

Urrum will not engage or continue working with a third party where there is a reasonable basis to believe that bribery, corruption or other serious integrity concerns are present and cannot be adequately mitigated.

Procurement, sourcing and supplier integrity

Because Urrum operates in procurement, sourcing and contract support activities, integrity in supplier and counterparty engagement is essential.

Urrum personnel must not:

• manipulate specifications to favour a preferred party improperly;
• disclose confidential bid or evaluation information without authorisation;
• split requirements or alter processes to avoid controls;
• accept kickbacks, rebates or personal benefits from suppliers;
• create false urgency or non-competitive justifications without valid grounds;
• approve vendors, invoices or variations dishonestly or without appropriate basis.

Supplier selection, commercial evaluation, negotiation and award decisions must be made using fair, documented and defensible criteria.

Accurate books and records

All transactions and business dealings must be recorded accurately, completely and in reasonable detail.

Urrum prohibits:

• false, misleading or incomplete books and records;
• hidden accounts or off-book arrangements;
• mischaracterised payments or vague descriptions intended to obscure purpose;
• sham consultancy, agency or subcontracting arrangements;
• unsupported reimbursements or undocumented expenses.

No employee or representative may approve or process a payment unless they are satisfied that it is legitimate, properly supported and compliant with this Policy and Urrum procedures.

Red flags

The following may indicate elevated bribery or corruption risk and must be assessed carefully:

• requests for cash payments or unusual payment methods;
• pressure for urgent payment without normal documentation;
• refusal to provide ownership or company information;
• requests to use third parties with no clear role or capability;
• excessive commissions, success fees or unexplained mark-ups;
• offshore payment requests unrelated to the place of performance;
• family, political or government links not previously disclosed;
• gifts or hospitality around tender, permit or approval milestones;
• vague scopes of work or poorly documented services;
• resistance to contractual compliance provisions or audit rights.

The presence of a red flag does not automatically mean misconduct has occurred, but it does require further review before proceeding.

Speaking up and raising concerns

Everyone working for or on behalf of Urrum is expected to speak up if they become aware of conduct that may breach this Policy, the law or Urrum’s standards of integrity.

Concerns should be raised promptly through available channels, including:

• line management;
• company leadership;
• designated compliance or legal contacts;
• any formal internal reporting channel made available by Urrum.

Urrum will take reported concerns seriously, review them appropriately and seek to address them in a fair and timely manner.

Urrum prohibits retaliation against any person who raises a concern in good faith, even if the concern is ultimately not substantiated.

Responsibilities

Management

Management is responsible for:

• promoting a culture of integrity;
• ensuring personnel understand this Policy;
• implementing proportionate controls;
• escalating and addressing concerns promptly;
• ensuring appropriate documentation and approvals are maintained.

Employees and representatives

All personnel are responsible for:

• understanding and complying with this Policy;
• using sound judgement;
• identifying and escalating red flags;
• refusing improper requests;
• keeping accurate records;
• completing any required training or attestations.

Consequences of breach

Breaches of this Policy are taken seriously.

Any failure to comply may result in disciplinary action, which may include:

• counselling or formal warning;
• removal from a project or role;
• termination of employment or engagement;
• suspension or termination of third-party relationships;
• referral to law enforcement or regulators where required.

Key terms

Bribe

Anything of value offered, promised, given, requested or accepted to improperly influence a decision, action, inaction or outcome.

Corruption

The abuse of entrusted power, position or influence for private gain or improper advantage.

Facilitation payment

An unofficial payment made to secure or accelerate a routine governmental action.

Gift

Any item, benefit or advantage provided without full market-value consideration.

Hospitality / entertainment

Meals, events, travel, accommodation or other benefits provided or received in connection with business activity.

Public official

Any person acting in an official capacity for or on behalf of a government, regulator, public body, state-owned entity, political party or public international organisation.

Third party

Any external individual or entity engaged by, representing or acting on behalf of Urrum, including consultants, subcontractors, sourcing intermediaries, agents, logistics partners and service providers.

Governance and review

This Policy is owned by Urrum management and shall be reviewed periodically to ensure that it remains appropriate to the company’s operating model, risk profile and applicable legal requirements.

Urrum may issue supporting procedures, approval thresholds, registers and guidance notes to implement this Policy effectively.