Global Anti-Bribery and Corruption Policy

Anti-Corruption

Corrupt practices can be called by many names, but whatever the label, you must always avoid all corrupt practices, including these activities:

Bribery - giving or offering anything valuable to improperly influence the recipient. Bribery can involve anything that is valuable: cash, gifts, entertainment, payments to a third party (including a charity), offers of employment--anything valuable. You should not give, offer, or accept a bribe; if anyone gives or offers a bribe to you or any employee of Bynder, inform the Chief Legal Officer immediately.

Facilitation Payment - a payment made to a government official to encourage the official to take routine government action. This does not include official fees charged by a government.

Kickback - returning a portion of money paid (or money due) as an improper incentive to direct business to the payor. You should not give, offer, or accept a kickback; if anyone gives or offers a kickback to you or any employee of Bynder, inform the Chief Legal Officer immediately.

Gifts

All gifts--including meals and entertainment--must have a reasonable, non-corrupt business purpose and must be reasonable in value.

Applicable Laws

Bynder requires its employees to comply with this global policy as a minimum standard. Applicable laws such as the Foreign Corrupt Practices Act (United States), the Bribery Act (United Kingdom), the anti bribery and anti-corruption provisions in the Dutch Criminal Code (The Netherlands) may set higher or more specific standards; all applicable laws must also be followed to the utmost.