PLEASE NOTE CHAYTON CAPITAL LLP OPERATES
A STRICT ANTI-CORRUPTION POLICY

It is Chayton Capital LLP’s policy to conduct our business with integrity and in an honest and ethical manner pursuant to both the requirements, and also in keeping with the spirit of, anti-corruption legislation.

Chayton Capital LLP takes a zero-tolerance approach to bribery and corruption. We have therefore adopted a stringent anti-corruption policy, as well as rigorous internal anti-bribery procedures, to ensure our business practices are of the highest standards. We encourage the application of our policy amongst our business partners including contractors, suppliers and affiliates.

We expect our employees and those representing Chayton Capital LLP both in the UK and abroad to adhere strictly to our anti-corruption policy at all times. As such, we operate regular anti-corruption training for all our employees. Our anti-corruption policy prohibits employees and those representing Chayton Capital LLP from engaging in corrupt activity in any part of the world and requires them to report any occasion on which they are invited, or suspect that others have been invited or have made an invitation, to act corruptly. Our policy also provides guidance on the giving and receipt of gifts and hospitality. For these purposes, acting corruptly means engaging in any activity, practice or conduct which would infringe any anti-bribery and anti-corruption laws, regulations, codes or guidance, including but not limited to the Bribery Act 2010. We also have a clear reporting procedure for our employees to refer any possible instances of bribery or corruption.

Should you believe that any person or persons acting on behalf of Chayton Capital LLP has acted, or is acting, in such a way as to breach or potentially breach our anti-corruption policy, or if such persons are not acting in keeping with the spirit of our anti-corruption policy, please notify David Allen, our anti-corruption officer, at: david.allen@chaytoncapital.com