This Anti-Bribery & Corruption Policy outlines the standards and controls applied by Mohr & Coleman (“Mohr & Coleman”, “we”, “us”, “our”), a trading name of Ricochet Group Ltd, to prevent bribery and corruption in all business activities.

This policy applies to all employees, contractors, suppliers, and partners acting on our behalf.

1.1 The purpose of this policy is to ensure that Mohr & Coleman conducts business in an honest, transparent, and lawful manner.

1.2 This policy supports our obligations under applicable anti-bribery and corruption laws, including the Bribery Act 2010.

2.1 We take a zero-tolerance approach to bribery and corruption.

2.2 We do not permit any form of: bribery; facilitation payments; kickbacks; or improper inducements.

2.3 This applies whether such conduct is direct or indirect, and regardless of local business practices.

3.1 Individuals must not: offer, promise, give, request, or accept any financial or other advantage intended to influence a business decision improperly; engage in any activity that could be perceived as bribery or corruption; or use third parties to carry out actions that would be prohibited if undertaken directly.

3.2 No individual will be penalised for refusing to engage in bribery, even if this results in loss of business.

4.1 Reasonable and proportionate hospitality or business courtesies may be permitted where they are: appropriate in value and nature; provided transparently; compliant with applicable laws; and not intended to influence a decision improperly.

4.2 Gifts or hospitality must not: create an obligation or expectation of favourable treatment; be excessive, frequent, or inappropriate; or be offered or accepted during active procurement or tender processes where this could influence outcomes.

5.1 Individuals must avoid situations where personal interests conflict, or may reasonably be perceived to conflict, with the interests of Mohr & Coleman or its clients.

5.2 Any actual or potential conflict of interest must be disclosed promptly.

6.1 Mohr & Coleman may be held responsible for the actions of third parties acting on its behalf.

6.2 Individuals engaging third parties must: act reasonably in selecting partners and suppliers; avoid relationships that present a known risk of bribery or corruption; and ensure that third parties are aware of expected standards of conduct.

7.1 Accurate and transparent records must be maintained in relation to: financial transactions; expenses; and business activities.

7.2 Records must not be falsified, misleading, or incomplete.

8.1 Individuals are expected to report any suspected or actual: bribery; corruption; or unethical conduct.

8.2 Reports should be made promptly through appropriate internal channels.

8.3 Concerns will be treated seriously and handled appropriately.

9.1 All individuals are responsible for complying with this policy.

9.2 Failure to comply may result in: termination of engagement; removal from projects; or other appropriate action.

10.1 This policy may be updated from time to time to reflect changes in legal, regulatory, or operational requirements.

10.2 Mohr & Coleman will review this policy periodically to ensure it remains appropriate to the size and nature of the business.