Anti-Bribery & Corruption Statement

Treasure Well is committed to conducting business with the highest standards of integrity, transparency, and ethical conduct. We have a zero-tolerance policy toward bribery, corruption, and any form of illicit financial conduct.

This Anti-Bribery & Corruption Statement outlines the firm’s legal obligations, ethical commitments, and compliance measures to prevent bribery and corruption in all aspects of our operations. All employees, consultants, business partners, and third-party service providers are expected to adhere strictly to the principles and policies set forth herein.

Non-compliance with this Statement may result in disciplinary action, contract termination, regulatory reporting, and potential civil or criminal liability.

Legal & Regulatory Compliance

Treasure Well complies with all applicable anti-bribery and anti-corruption laws and regulations, including but not limited to:

• UK Bribery Act 2010

• US Foreign Corrupt Practices Act (FCPA)

• OECD Anti-Bribery Convention

• United Nations Convention Against Corruption (UNCAC)

• European Anti-Corruption Legislation

• Financial Action Task Force (FATF) Recommendations

These laws impose criminal and civil liabilities for bribery and corruption offenses and require organizations to implement robust internal controls, monitoring mechanisms, and compliance programs.

Treasure Well is fully committed to complying with these legal frameworks and ensuring that all employees, affiliates, and business partners do the same.

Prohibited Conduct

Treasure Well strictly prohibits the following bribery and corruption-related activities:

Offering, Giving, or Receiving Bribes

• The firm prohibits offering, promising, authorizing, giving, soliciting, or accepting any form of bribe, kickback, or improper payment to or from any individual, organization, government official, or private entity.

• A bribe includes money, gifts, hospitality, favors, contracts, or any other item of value intended to influence a business decision, regulatory action, or improper advantage.

Facilitation Payments

• Facilitation payments (small, unofficial payments made to expedite routine governmental actions) are strictly prohibited.

• Employees and third parties must report any requests for facilitation payments immediately to the Compliance & Risk Office.

Gifts, Hospitality & Entertainment

• Gifts, entertainment, and hospitality may only be provided or accepted if they are:
  ✔ Reasonable in value and not excessive.
  ✔ Directly related to a legitimate business purpose.
  ✔ Not intended to improperly influence a business or regulatory decision.

• Any gifts or hospitality exceeding a pre-approved monetary threshold must be disclosed to the Compliance & Risk Office.

Political Contributions & Charitable Donations

• Treasure Well does not make political contributions to political parties, candidates, or public officials.

• Charitable donations must be transparent, properly documented, and not used as a means to disguise bribery or illicit financial transactions.

• All donations must be approved by the Ethics & Compliance Committee to ensure compliance with anti-bribery laws.

Third-Party & Supplier Integrity

• Treasure Well conducts due diligence on all third-party vendors, consultants, and service providers to ensure compliance with anti-bribery and anti-corruption laws.

• Any third-party found to be engaged in corrupt practices will be subject to contract termination and, where applicable, legal action.

Compliance Controls & Risk Mitigation

Mandatory Anti-Bribery Training

• All employees, executives, and consultants undergo mandatory anti-bribery and corruption training to ensure awareness of legal obligations and ethical standards.

• Training includes case studies, regulatory updates, and compliance risk assessments.

Due Diligence & Third-Party Vetting

• Treasure Well conducts thorough Know Your Business (KYB) and Know Your Customer (KYC) due diligence before engaging in transactions or partnerships.

• Third-party entities must undergo compliance screenings to assess bribery and corruption risks before contractual agreements are finalized.

Financial & Accounting Transparency

• All financial transactions must be accurately recorded and traceable to prevent the concealment of improper payments.

• Treasure Well prohibits undocumented transactions, off-the-books accounts, and falsified financial reporting.

Reporting Violations & Whistleblower Protections

Obligation to Report

• Employees, business partners, and stakeholders must immediately report any suspected or actual instances of bribery or corruption.

• Reports can be made confidentially to:
  Compliance & Risk Office: compliance@treasurewelllaw.co.uk
  Whistleblower Hotline (Confidential): ethics@treasurewelllaw.co.uk

Whistleblower Protections

• Treasure Well strictly prohibits retaliation against individuals who, in good faith, report suspected bribery, corruption, or unethical conduct.

• Whistleblowers are protected under UK employment laws, international anti-retaliation statutes, and corporate governance frameworks.

Internal Investigations & Enforcement

• All reports of suspected bribery or corruption will be promptly investigated by the Compliance & Risk Office.

• Violations will result in:
  ✔ Internal disciplinary actions, including termination of employment or contractual relationships.
  ✔ Regulatory reporting to law enforcement agencies where required.
  ✔ Civil and/or criminal legal proceedings under applicable anti-bribery laws.

Legal Disclaimer & Amendments

• This Anti-Bribery & Corruption Statement serves as a legally binding compliance policy governing Treasure Well’s operations and ethical obligations.

• Treasure Well reserves the right to revise, amend, or supplement this Statement in response to regulatory developments, law enforcement actions, or internal compliance reviews.

• This Statement does not create contractual rights for third parties, but serves as an internal governance framework for corporate compliance.