Anti Bribery & Corruption Policy

Introduction

OSRL is committed to the highest standards of integrity and aims to prevent conflicts of interest and protect the organisation and its employees from legal and reputational risks. It sets clear expectations for disclosing company information, avoiding bribery, acting against modern slavery and trafficking, and managing interactions with third parties-especially regarding gifts and entertainment OSRL is committed to conducting all business honestly, ethically, and in compliance with applicable laws, including the UK Bribery Act 2010. We operate a zero-tolerance approach to bribery, corruption, conflicts of interest, and modern slavery.

We expect all employees, members, suppliers, and third parties to act with integrity and transparency in all dealings. This includes:

Never offering, accepting, or authorising bribes or improper advantages.
Avoiding conflicts between personal interests and OSRL’s business.
Protecting confidential information and reporting any suspected misconduct.
Ensuring no involvement in forced labour, human trafficking, or exploitative practices.

Our Anti-Corruption & Integrity framework includes:

This policy and supporting procedures.
Clear rules and guidance for employees and third parties.
Mandatory training and awareness.
Defined responsibilities for compliance and reporting.
A whistleblowing mechanism for confidential reporting.

Violations may result in disciplinary action, including dismissal, and legal consequences. Suppliers and members are required to certify compliance with OSRL’s anti-bribery and integrity standards as a condition of engagement. We require all Employees to comply with OSRL Policies including the Anti-Bribery and Corruption Policy (“ABC Policy”) and procedures. Any breach of the ABC Policy and procedures constitutes a disciplinary offence and may amount to gross misconduct. There are various means for staff and third parties to report any concerns they might have, if need be, anonymously.

As part of OSRL’s commitment to integrity, all suppliers must provide their organisation’s Anti Bribery policy during onboarding, or complete and sign OSRL’s Anti-Bribery Certification of Compliance, confirming adherence to OSRL’s Anti-Bribery and Corruption (ABC) policies. This obligation extends to their affiliates, subcontractors, directors, officers, and employees.

Participant and associate members also commit to anti-bribery and anti-corruption standards through their membership agreements.

OSRL ensures the policy is communicated to all employees as part of their induction and ongoing annual elearning training. The policy is available to third parties on OSRL’s website.

This policy applies to all individuals working with or on behalf of OSRL, including employees (permanent, temporary, or contract), directors, officers, consultants, suppliers, members, agency staff, interns, volunteers, and affiliates collectively referred to as “Employees.”

Anti-Slavery / Human Trafficking

Oil Spill Response Limited (OSRL) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. OSRL has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain. The OSRL culture does not in any way condone slavery or human trafficking and would not entertain continuing business with any entity which did not adopt a similar stance and position.

All OSRL membership agreements have been updated to incorporate specific commitments to Anti- Slavery and Human Trafficking.

Due Diligence

There is a risk of slavery and human trafficking across our business, managed across all our permanent bases. As a response organisation, which may be called upon to operate in any area of the globe, including countries where the risk is perceived to be high, therefore there may be an increased risk in respect of temporary operations. All new sub-contactors are subject to an on-boarding and risk assessment process, with input from the group legal function as required to ensure compliant work practices are always maintained. We enforce strict compliance with this, and
do not tolerate breaches within our supply chains.

Training

We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

Anit-Bribery and Corruption

Our approach and what we expect of employees

OSRL strictly complies with all applicable laws and holds itself to the highest standards of integrity. While customs may vary globally, honesty is universally respected and essential to our reputation.

Employees must:

Act ethically and transparently in all business dealings.
Accurately record transactions and cooperate fully with auditors.
Report any suspected violations of law or company policy.
Complete annual Anti-Bribery and Corruption (ABC) training.

Unethical conduct, even if results are achieved, will not be tolerated. OSRL supports employees who uphold ethical standards, even at the cost of missed opportunities.

Managers are expected to lead with transparency and enforce compliance. Concealing information or bypassing controls undermines trust and can lead to organisational harm.

OSRL encourages reporting of ethical issues through the company’s ‘Speak Up’ facility, which provides a platform to report issues relating to bribery or corruption and Conlficts of Interest, as well as Whistleblowing.

OSRL protects whistleblowers from retaliation, as outlined in the Grievance & Whistleblowing Policy.

OSRL requires all transactions to be accurately recorded - falsifying records or maintaining off-the-book accounts is strictly prohibited.

Strong supplier and contractor relationships must never compromise ethical standards. In all dealings, employees must:

Respect the law and avoid corrupt practices.
Make honest commitments and deliver on them.
Fulfil obligations fairly and without coercion.
Use company assets responsibly and avoid personal gain through misuse of position.
Only give or accept modest, infrequent business gifts or entertainment.
Never make facilitation payments to expedite routine services.
Never retaliate against anyone who refuses to engage in bribery or reports concerns.
Employees are expected to uphold these standards and report any suspected misconduct.

We publish an annual statement on our website of our continued commitment to upholding Anti Bribery and Corruption principles.

Bribery and Facilitation Payments - General Prohibitions

Most countries prohibit corruption, and for OSRL, the Bribery Act 2010 outlines anti-bribery laws. Many nations also criminalize bribery committed abroad. Breaching these laws can lead to severe penalties, including corporate fines and individual imprisonment. Even the appearance of a violation can seriously damage OSRL’s and its Shareholders’ reputations.

Employees must not offer or promise anything of value-such as payments, gifts, services, or entertainment-to gain or retain business or secure any improper advantage. This includes indirect payments via third parties like agents or contractors.

Facilitation Payments (e.g., for speeding up permits or customs) are also prohibited, regardless of amount. However, if personal safety is at risk, low-value items (e.g., company shirts) may be offered first, with small cash payments only as a last resort. Any such payments must be reported promptly through OSRL’s internal reporting system.

Conflict of Interest - Statement of General Principle

OSRL policy requires all Employees to avoid conflicts between personal interests and the Company’s interests when dealing with suppliers, customers, and third parties, as well as in their personal conduct, in compliance with the Companies Act 2006 and Bribery Act 2010.

It is also a conflict of interest for an Employee-during or after employment and without proper authorization-to disclose or use confidential information gained through their role for personal benefit.

Employees must avoid any conflict between personal interests and OSRL’s business dealings. It is also prohibitedduring or after employment-to use or share confidential information without proper authorisation.

Conflicts of Interest - Examples to Avoid

While not exhaustive, the following situations are considered conflicts of interest and must be avoided unless approved in writing by management:

Having a personal or family interest in an organisation doing or seeking business with OSRL where preferential treatment could occur.
Competing with OSRL through outside business activities.
Serving as an officer, director, consultant, or manager for a company doing or seeking business with OSRL.
Approving contracts involving immediate family or their employers under your control-these must be escalated to management.
Sharing or using confidential OSRL information without authorisation.
Accepting gifts (beyond nominal value), commissions, payments, loans, or excessive entertainment from third parties.

Employees must consult their line manager if unsure whether a situation may present a conflict. Managers will escalate to senior leadership as needed, following OSRL’s Gifts and Entertainment Guidelines.

Guidelines for Gifts

These guidelines apply to all Employees.

Gifts must be given or received with care to avoid misinterpretation-such as appearing to influence decisions, enhance personal lifestyles, or misuse Company funds. OSRL and its Employees risk being seen as having double standards if they give more generously than they accept, or as being obligated to reciprocate. The risk increases if the gift or entertainment is offered privately.

Gifts of nominal value are generally acceptable if:

The recipient values it appropriately;
It does not create a sense of obligation;
The Employee would not be embarrassed if it became public;
There is no intent to improperly gain business or advantage;
The recipient is not a Public Official.

If a gift may be seen as more than nominal, the Employee must consult their line manager, who should seek written approval from senior management.

No sponsorships, charitable, or political donations may be made on behalf of OSRL without Senior Management approval. Personal donations and sponsorships are permitted.

For further detail please consult the Guideline for Gifts Procedure.

Anti-Money Laundering Commitment

Oil Spill Response Limited (OSRL) is committed to conducting its business in full compliance with all applicable antimoney laundering (AML) laws and regulations. While our Anti-Bribery and Corruption Policy outlines our zerotolerance approach to unethical conduct, we also recognise the importance of preventing the misuse of financial systems for illicit purposes.

OSRL maintains robust financial controls, accurate record-keeping practices, and transparent audit procedures to ensure that all transactions are legitimate and traceable. We do not engage in or condone any activity that could facilitate money laundering, including the concealment of funds, misrepresentation of financial records, or use of off-the-record accounts.

All employees, contractors, and suppliers are expected to uphold these standards and report any concerns related to financial integrity or suspicious activity. OSRL will continue to monitor and strengthen its compliance framework to ensure alignment with international AML best practices.

Consequences of Breaching this Policy

Violating this policy may lead to investigation and disciplinary action under OSRL’s Disciplinary Policy. Serious breaches that damage the Company’s reputation may be considered gross misconduct and result in dismissal.

Separately, breaches may also constitute criminal offences under the Bribery Act 2010 or the Foreign Corrupt Practices Act 1977-both of which can apply globally. Conviction under the Bribery Act can result in up to 10 years’ imprisonment and unlimited fines.

Leaving

All Company property and documents-including instructions, procedures, and reports-must be returned upon leaving OSRL, unless written approval is granted by a member of the Executive Team.

Responsibility and Compliance Management

Employees must raise any concerns through OSRL’s ‘Speak Up’ facility. Alternatively they may speak with the Assurance, Risk and Compliance Officer, or their line manager, who will advise or escalate as needed.

The Assurance, Risk and Compliance Officer, supported by the Group Legal Counsel, is responsible for promoting awareness and updates to the policy. Line managers must ensure policy compliance, investigate issues, and protect both Employees and the Company from compromise.