Anti-bribery Policy Statement and Objectives

Manitou Centres SA is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented.

Manitou Centres SA has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly and with integrity in all business dealings and relationships, wherever in the country we operate.

Manitou Centres SA will constantly uphold all laws relating to anti-bribery and corruption in all jurisdictions in which we operate. We are bound by laws of The Republic of South Africa, including the PREVENTION AND COMBATING OF CORRUPT ACTIVITIES ACT, regarding our conduct both at home and abroad.

Manitou Centres SA recognises that bribery and corruption are punishable by imprisonment for a term which shall be not less than six months, but which may extend to five years and shall also be liable to a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to a strict fine, be excluded from tendering for public contracts, and face serious damage to our reputation. With this in mind, we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

Definition of Bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value, or an advantage, so as to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Manitou Centres SA employees will not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They may not bribe a foreign public official anywhere in the world. They may not accept bribes in any form and, if they are uncertain about whether something is a bribe, a gift or an act of hospitality, they must seek further advice from the company’s Financial Manager.

Customer Undertaking

As a Manitou Centres SA customer/dealer we request that you:

• Not partake in any form of corruption or bribery and ensure that business decisions are not influenced through any improper or illegal payments, either through cash, gifts, travel or anything else of value (including intangible benefits).
• Refrain from presenting any invitations, gifts, or anything of value to Manitou Centres SA employees with an intention to gain any form of influence.
• Disclose to Manitou Centres SA any requests or pressure to provide bribes or any other kind of benefit in any form, either to public officials or any other parties, directly or indirectly, that may try to influence or provide an unfair business advantage.
• Avoid situations where your own interests conflict, or could conflict, with the business interests of Manitou Centres SA.
• Notify Manitou Centres SA, without delay, if you are aware of a conflict of interest, including if a Manitou Centres SA employee has a financial interest in the customer’s/dealer’s company or is in any way related the customers’/dealer’s company.

Whistleblowing

Please notify Manitou Group of any suspected or confirmed bribery related by reporting your concern on the link that follows https://secure.ethicspoint.eu/domain/media/en/gui/105305/index.html.

Manitou Centres SA undertakes to ensure confidentiality of your report and personal details (in accordance with our Protection of Personal Information Policy).