Anti-Bribery, Corruption and Sanctions Policy

1. Zero-tolerance standard

Bridgehampton prohibits bribery, corruption, kickbacks, facilitation payments, secret commissions, money laundering, sanctions evasion, and false books or records. This Policy applies worldwide to the Company, controlled subsidiaries, directors, officers, employees, and third parties acting for or on behalf of the Company.

2. Applicable laws

Covered persons must comply with the U.S. Foreign Corrupt Practices Act, applicable U.S. anti-kickback and fraud laws, U.S. economic sanctions and export controls, the UK Bribery Act where applicable, and host-country laws. A local custom or instruction does not excuse a violation.

3. Prohibited conduct

• Offer, promise, authorize, give, request, or accept anything of value to obtain an improper advantage or influence an official or commercial decision.
• Make facilitation or expediting payments, except a payment necessary to address an imminent threat to health or safety, which must be reported and accurately recorded immediately.
• Use an agent, consultant, joint venture, charity, supplier, family member, or other intermediary to do indirectly what the Company cannot do directly.
• Structure, route, omit, misdescribe, or conceal a transaction to avoid sanctions, screening, approval, tax, or recordkeeping controls.
• Create an undisclosed fund, false invoice, sham service, excessive commission, off-book account, or misleading entry.

4. Government officials

Government Official includes any officer or employee of a government, regulator, state-owned or state-controlled enterprise, public international organization, political party, candidate, royal household acting officially, or person acting for them. Because petroleum rights, permits, customs, taxation, security, and state-owned energy companies frequently involve officials, all government-facing intermediaries require enhanced due diligence and written Legal approval.

5. Gifts, travel, hospitality, and expenses

Cash and cash equivalents are prohibited. Gifts and hospitality must be lawful, reasonable, infrequent, transparent, business-related, accurately recorded, and never tied to a pending decision. Anything for a Government Official requires advance Legal approval. Items above USD 250 per person, or a lower local limit, require advance written executive and Legal approval and entry in the gifts register.

6. Political and charitable contributions

No Company political contribution may be made without Board or expressly delegated approval and Legal review. Charitable contributions and sponsorships require due diligence, a legitimate purpose, a written agreement, verification of recipient, and controls against diversion. Contributions may not be used to influence an official or secure business.

7. Third-party due diligence

Risk-based due diligence is required before engagement and periodically thereafter for agents, distributors, brokers, customs advisers, security providers, consultants, joint ventures, acquisition targets, suppliers, customers, and other high-risk counterparties. Red flags must be resolved and documented. Contracts must include compliance representations, audit and termination rights, payment controls, and accurate service descriptions.

8. Sanctions and export controls

Relevant parties, beneficial owners, vessels, banks, countries, and transactions must be screened against applicable sanctions and restricted-party lists. No transaction may proceed where a prohibited interest, blocked property, embargo, export restriction, evasion concern, or suspicious routing exists without written Legal clearance and any required license.

9. Books, records, and internal controls

Transactions must be supported, approved under delegated authority, recorded accurately and in reasonable detail, and paid to a verified account in the contracting party's name unless Legal and Finance approve a documented exception. No employee may bypass controls by splitting invoices, changing descriptions, using cash, or directing payment through unrelated entities.

10. Training, monitoring, and certification

Risk-based training is mandatory for relevant personnel and third parties. High-risk employees and intermediaries may be required to certify compliance annually. Compliance will conduct risk assessments, transaction testing, audits, and monitoring proportionate to country, counterparty, payment, government touchpoint, and sector risk.

11. Reporting, investigations, and consequences

Report suspected violations, demands, red flags, retaliation, or inaccurate records immediately through the Code or Whistleblower channels. No retaliation is permitted. The Company may suspend transactions, withhold payment, investigate, discipline, terminate, recover losses, disclose to authorities, and remediate controls.