Anti-Bribery and Corruption Policy

The Nero Blanco Group is committed to conducting business fairly, honestly and with integrity. Our reputation is built on the values of our organisation, the professionalism of our people and our commitment to ethical conduct in every aspect of our business.

For the purposes of this policy, the "Nero Blanco Group" means Nero Blanco IT Limited, Declaration Software and Nero Blanco Inc all of its current and future subsidiaries, affiliated companies and other entities that adopt this policy (each a "Group Company").

The Nero Blanco Group has a zero-tolerance approach to bribery and corruption. We will not tolerate bribery or corruption in any form, whether committed by our employees, officers, directors, contractors, consultants, agents or any third party acting on behalf of a Group Company.

From within our day-to-day working environments, it can sometimes be difficult to appreciate the wider impact of bribery and corruption. However, these are not victimless crimes. As Kofi Annan, former Secretary-General of the United Nations, observed:

"Corruption … undermines democracy and the rule of law, leads to violations of human rights, distorts markets, erodes the quality of life and allows organised crime, terrorism and other threats to human security to flourish. This evil phenomenon is found in all countries – big and small, rich and poor… corruption hurts the poor disproportionately by diverting funds intended for development, undermining a government's ability to provide basic services, feeding inequality and injustice and discouraging foreign aid and investment. Corruption is a key element in economic under-performance and a major obstacle to poverty alleviation and development."

Our Anti-Bribery and Corruption Policy reflects these principles and applies throughout the Nero Blanco Group. Everyone working for or on behalf of a Group Company is responsible for familiarising themselves with this policy and complying with its requirements.

The Nero Blanco Group reserves the right to terminate any business relationship or contract where there is evidence of bribery, corruption or other unethical conduct.

Bribery is a criminal offence. Under the UK Bribery Act 2010, organisations may be subject to unlimited fines, while individuals may face fines and/or imprisonment for up to ten years.

We are committed to preventing bribery and corruption and to fostering a culture in which everyone is encouraged to act honestly, ethically and with integrity. We will support anyone who raises genuine concerns or refuses to participate in bribery or corruption, even where doing so may result in the loss of business or commercial opportunities.

Signed:

Antonios Van Beers

Neil Langston

Conrad Murray

For and on behalf of the Nero Blanco Group

Nero Blanco