Genel does not tolerate bribery in any form and is committed to complying with all applicable laws and preventing, detecting, and deterring corruption in all its business dealings.

Set out below are the six essential elements of Genel’s Anti-bribery Compliance Programme:

Leadership and Top-Level Commitment: Genel’s Anti-bribery policy and procedures are fully endorsed by the Board and Senior Management. This is supported by collaboration amongst the company stakeholders such as, operational managers, finance, procurement and human resources. We all demonstrate collective commitment to fostering a culture of compliance with our “ZERO” tolerance to bribery.

Policies and Procedures: Adopting a proportionate and risked based approach to anti-bribery risks, we have controls in place regulating certain interactions of Genel staff with government and/or non-government officials. Gifts, entertainment, accommodation, travel or anything of value to third parties are required to be reviewed before being offered to ensure they are legal and appropriate in all the circumstances. Certain business courtesies are prohibited, and others must be pre-approved by the Legal Department before being offered. The thresholds at which approvals are required for these purposes are set out in our Anti -Bribery Procedures. Genel also has in place controls around the use of cash in the locations where we operate.

Risk Assessment: We assess compliance risks periodically to evaluate the degree to which Genel’s staff conduct business with government officials, third parties and any intermediaries.

Due Diligence: We have due diligence procedures that must be followed before any Business Partners are engaged. Any red flags are assessed and, where appropriate, remediated to mitigate any specific compliance related risks.

Training and Communication: Genel’s leadership communicates the importance of anti-bribery compliance and this is supported through online training and periodic face to face training. Training is adapted as the regulatory environment develops.

Oversight: To maintain adequate oversight of our compliance programme, we have adopted (i) monitoring, (ii) auditing / periodic compliance reviews and (iii) responding to issues raised as our three key activities. Periodic updates are given to the Audit Committee of the Board.

Further details are contained in our Anti-Bribery Policy and our Anti-Bribery Procedures.

Genel is a member of TRACE  International, a globally recognized anti-bribery business organisation which helps companies conduct business ethically and in compliance with the U.S. Foreign Corrupt Practices Act, U.K. Bribery Act and other anti-bribery legislation.

Genel is also a member of Transparency International UK, a global movement sharing one vision: a world in which government politics, business, civil society and the daily lives of people are free of corruption.