Anti-Bribery Third Party Policy March 2021

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Classification: PublicGROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERSGROUP ANTI-BRIBERY POLICYSUMMARY FOR THIRD PARTY SUPPLIERSRATIONALEGroup Policy RationaleThis Policy has been designed to assist in managing the risk of payments, offers,promises of a bribe (making a bribe) or receipt, requests or acceptance of a bribe(being bribed) by an individual or associated party. The overall risk includes thefollowing risk drivers: Failure to comply with anti-bribery legislation both in the UK and in the otherjurisdictions in which Lloyds Banking Group (the Group) operates; Failure to maintain consistent, proportionate and effective approach to antibribery; Failure to respond effectively to 'an offer or acceptance of any gift, fee,reward or other advantage to or from any person as an inducement to dosomething improper in the conduct of the Group's business, which isdishonest, illegal or a breach of trust’. This includes offers and promises togive as well as requests and agreements to receive bribes.In addition, this Policy has been designed to support compliance with the followinglegislation and / or regulations: Bribery Act 2010, in particular sections 1, 2 and 7 which enable theprosecution of individuals and commercial organisations; Bribery Act 2010 Guidance about procedures which relevant commercialorganisations can put into place to prevent persons associated with themfrom bribing (section 9 of the Bribery Act 2010) including the six Ministry ofJustice (MoJ) principles;Proceeds of Crime Act (POCA) 2002; Financial Conduct Authority (FCA) Handbook - Principles for Business, inparticular, principles 1, 2, 3 and 8; FCA Financial Crime – a Guide for Firms (in particular Part 1 – sections 2 & 6,Part 2 – sections 9 & 13); US Foreign Corrupt Practices Act 1977; and Any other jurisdictional legislation that has extra-territorial application.The Group has a moral and ethical duty to act with the highest standards of integrityand honesty in all it does. This Policy builds on the Group's corporate responsibilityto its customers, shareholders and colleagues to deter, prevent, detect and respondto those who would seek to use the Group to facilitate any form of financial crime.The Group has no appetite for breaching bribery legislation and/or regulation. Thisincludes activities conducted by an external party supplying services for or on behalfof the Group, or acting on the Group’s behalf (the “Supplier”).In jurisdictions where the local legislative and regulatory requirements exceed theLLOYDS BANKING GROUP - PUBLICV8.0 September 2020Page 1 of 6

Classification: PublicGROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERSrequirements set out in this document, the Supplier must comply with such higherstandards.Customer ImpactThe Group’s vision is to be the best bank for customers. The Group Anti-BriberyPolicy supports this vision and the aim of providing investors with strong, stable andsustainable returns by: Complying with legal and regulatory requirements; Understanding the Group’s risk appetite; Implementing internal processes and controls including appropriate riskassessment to mitigate the risk of bribery; and Receiving adequate training and thereby understanding how to act in anethical manner.SCOPEThis third party version of the Policy applies to suppliers where it has been identifiedthat the Group Policy applies to the provision of their goods and or services.MANDATORY REQUIREMENTS – GENERALPrincipal prohibitionThe Supplier, and anyone engaged by the Supplier to act for or on behalf of theGroup, must not:a. offer, promise, give, request, agree to receive or accept a bribe; orb. do anything to circumvent controls in place to deter, prevent or detect bribery.Required proceduresIn order to comply with legislative requirements, the Group’s approach to managingthe risk of bribery is informed by the six core principles contained in the UK Ministryof Justice Guidance issued under Section 9 of the UK Bribery Act 2010.The Supplier must ensure that in respect of the activities carried out for or on behalfof the Group, it operates procedures (including controls, processes and operations)designed to manage the risk of bribery, which are: proportionate to the bribery risk (as identified through a risk assessmentexercise); appropriate and relevant for the type of business; communicated to relevant parties (internal and external), including the Group; documented in a clear comprehensible manner and accessible to all relevantpersons; and reviewed regularly to ensure they remain up-to-date and reflect currentpractice.Prevention of CorruptionCorruption is defined as the abuse of entrusted power for private gain and is a termused to describe a wide range of financial misconduct.The Group has zero appetite for acts of corruption committed by colleagues,customers or suppliers. Any incidents or potential incidents of corruption (byemployees of the Supplier or any other persons who will perform services on behalfof the Group) must be reported in accordance with the reporting requirements of thisand any related policies that deal with activities that fall under the definition ofcorruption.LLOYDS BANKING GROUP - PUBLICV8.0 September 2020Page 2 of 6

Classification: PublicGROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERSDealings with Public Officials may pose a greater corruption risk due to their positionand status. Under section 6 of the Bribery Act 2010 it is a specific offence to bribe aforeign public official. Suppliers must, when dealing with any Public Official, ensurethat appropriate steps are taken to minimise the bribery and corruption risksassociated with relationships of this nature.Top Level CommitmentEffective top level commitment allows an organisation to drive an appropriate andeffective anti-bribery culture. Suppliers may consider appointing a nominatedindividual(s) with technical expertise and professional credibility to be responsible forthe management of anti-bribery risk in a similar manner to the structure utilised withinthe Group.Threat and Risk AssessmentThe purpose of a risk assessment is to allow the supplier to identify and mitigatebribery risks associated with the conduct of their business.The supplier must undertake a regular anti-bribery risk assessment in order toidentify and mitigate the bribery risks associated with the conduct of its business.The supplier must ensure that all risks identified are managed and mitigated by theapplication of its anti-bribery controls.Due diligenceThe purpose of due diligence is to identify and mitigate the risk that a bribe is offeredto obtain or retain business relating to the Group, or an advantage in the conduct ofthe Group or the supplier’s business.The supplier must complete risk-based anti-bribery due diligence on persons(including individuals and incorporated or unincorporated bodies) who will performservices for or on behalf of the Group which is appropriate and relevant to suchservices. Further guidance on risk-based due diligence can be obtained from yoursupplier manager if required.In determining whether a person is acting for or on behalf of the Group, the suppliermust consider the nature of the activity being undertaken. As a minimum, an agent,subsidiary or any other person obtaining, retaining or conducting business on behalfof the Group must be subject to due diligence.The supplier must, as part of their due diligence activities, identify all directors andperform appropriate additional checks to ascertain whether or not any of the directorsare public officials and/or politically exposed persons (PEPs). Where the nature ofthe services provided and the involvement of public officials and/or PEPs leads to anincrease in bribery risks, further guidance must be sought from your suppliermanager.Due diligence for employeesThe supplier must assess the need for, and extent of, ongoing due diligence forpersons engaged by it to identify and mitigate bribery risks.Monitoring and ReviewThe supplier must ensure that arrangements are in place to monitor regularly thecontinued adequacy and effectiveness of processes, systems and controls in order toLLOYDS BANKING GROUP - PUBLICV8.0 September 2020Page 3 of 6

Classification: PublicGROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERSassess compliance with this document. This will include any assurance, oversightand/or audit reviews.Where deficiencies are identified, suppliers must resolve them without delay,escalate to the Group where appropriate and monitor thereafter to identify andprevent any recurrence.Gifts, Entertainment & HospitalityThe supplier must not offer, either personally or on behalf of the Group, gifts,entertainment and hospitality (GEH) intended to unduly influence a decision-maker,supplier or customer in order to gain or retain business on behalf of the Group.Suppliers must perform analysis of GEH records to ensure that any GEH offered orreceived is proportionate and relevant to both an individual’s role and the relationshipbetween the supplier and the offeror or recipient of the GEH.When analysing GEH, suppliers need to be aware of the following “Red Flags” andmust escalate any instances where any or all of these factors are present: Anomalies or 'out of Policy' GEH offered or received; The timing of the offer or receipt of GEH in relation to contract or other relatednegotiations; and Any GEH that has not been recorded and/or reported.Charitable DonationsThe supplier must not make any donations to charities for or on behalf of the Group.Political DonationsThe supplier must not make any political donations for or on behalf of the Group.Facilitation PaymentsFacilitation payments are illegal under UK law. A facilitation payment is a paymentwhich is made to expedite or secure the performance of a routine non-discretionaryaction, such as processing papers, issuing permits, and other actions by a personwhich they are already bound to perform.Facilitation payments which relate in any way to the services provided to LloydsBanking Group are prohibited. In exceptional circumstances of duress (only wherethere is a threat to life, limb or liberty) facilitation payments may have to be made.Where possible, prior approval from the Group must be obtained. In any event, allsuch facilitation payments must be reported to the Group immediately.The supplier must ensure that: the risk of facilitation payments which relate in any way to the servicesprovided to the Group being requested is included in their risk assessment; all requests for such facilitation payments are reported to the Group; suitable procedures to mitigate the risk are in place where there is a likelihoodthat facilitation payments will be requested (e.g. in certain jurisdictions).These procedures must include specific training for individuals who may haveto manage such requests; and all those acting for or on behalf of the Group are aware of their responsibilitiesin respect of facilitation payments even where these are declined or refused.LLOYDS BANKING GROUP - PUBLICV8.0 September 2020Page 4 of 6

Classification: PublicGROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERSReportingThe supplier must ensure that all persons engaged by it are aware of routes to reportinstances of suspected bribery or attempted bribery.To the extent permitted under applicable law, the supplier will, as soon as isreasonably practicable, notify the Group in the event that a person acting on its or theGroup’s behalf is suspected of bribery or corrupt practices. The supplier will promptlynotify the Group if the supplier, or any person engaged by it, is prosecuted, chargedwith or convicted of any bribery-related offence.Record KeepingThe supplier must retain all records (electronic and paper, and including relevanttraining records) in line with the requirements found in the Group Data Third PartyPolicyTrainingThe supplier should ensure that all employees complete anti-bribery training andawareness activities appropriate to both their individual roles and the level of briberyrisk associated with the role.Where employees are identified as working in roles considered high risk for briberyrisks role specific training should be considered to ensure that employees are awareas to the increased bribery risks associated with their roles.KEY CONTROLSControl TitleAnti-Bribery TrainingAnti-Bribery Trainingfor New StartersAnti-BriberyReportingControl DescriptionAnti-Bribery training must be completedannually by all employees of thesupplier (where they provide goods andservices to the Group that mayintroduce bribery risk).FrequencyQuarterlyAll new employees must completemandatory Anti-Bribery training within 8weeks of commencing employment withthe supplierKey management information issubmitted to the Group via thesupplier's usual Group contact; theinformation provided is accurate, timelyand approved for submission. Keymanagement information includes, butis not limited to, information in respectof Training, GEH, Charitable Donations,Political Donations, FacilitationPayments and high risk third parties.QuarterlyMonthlyMANDATORY REQUIREMENTS – NON-COMPLIANCEAny material differences between the requirements set out above and the supplier’sown controls should be raised by the supplier with the Group’s supplier manager.The supplier manager will then discuss the non compliance with the AccountableLLOYDS BANKING GROUP - PUBLICV8.0 September 2020Page 5 of 6

Classification: PublicGROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERSExecutive for the relationship and local risk team to agree way forward.Version Number6.07.08.0Next Planned Revision: July 2021Effective DateJune 2018June 2019September 2020LLOYDS BANKING GROUP - PUBLICV8.0 September 2020Page 6 of 6

bribery risks associated with the conduct of their business. The supplier must undertake a regular anti-bribery risk assessment in order to identify and mitigate the bribery risks associated with the conduct of its business. The supplier must ensure that all risks identified are managed and mitigated by the application of its anti-bribery controls. Due diligence The purpose of due diligence is .

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