LCH.Clearnet Anti-Bribery Policy

It is the policy of LCH.Clearnet to conduct all of our business in an honest and ethical manner. We place the highest value on our reputation and take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, implementing and enforcing effective systems to counter bribery by:

• Setting out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

• Providing information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

The policy
LCH.Clearnet prohibits:

• Giving, promising to give, or offering a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or rewarding a business advantage already given;

• Giving, promising to give, or offering a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;

• Accepting payment from a third party with the expectation that it will obtain a business advantage for them;

• Accepting a gift or hospitality from a third party if known or suspected that it is offered or provided with an expectation that a business advantage will be provided by us in return;

• Threatening or retaliating against another worker who has refused to commit a bribery offence or who has raised concerns under the LCH.Clearnet policy; or

• Engaging in any activity that might lead to a breach of the LCH.Clearnet policy.

Responsibility
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for LCH.Clearnet or under LCH.Clearnet’s control. All LCH.Clearnet staff and contractors are required to avoid any activity that might lead to, or suggest, a breach of this policy.

If a third party is found to be bribing or attempting to bribe an employee of LCH.Clearnet, business dealings will cease immediately.