DLA Piper has a strict anti-bribery and corruption policy which applies to all our people globally. We will not directly or indirectly engage in bribery or corruption in any form and have a zero tolerance approach to breach, whether it involves private individuals or public officials. We will never accept, solicit, agree to receive, promise, offer or give a bribe, facilitation payment, kickback or other improper payment.

For this purpose, "bribe" means a financial or other advantage, intended to induce a person to give improper assistance in breach of their duty, or to otherwise improperly influence someone with the underlying purpose of obtaining/retaining business, or an advantage in the course of business, and "facilitation payments" are small bribes made to government or public officials to speed up routine administrative processes or other actions.

All of our activities are managed in full compliance with this policy and with all applicable legal and regulatory anti-bribery and corruption obligations. We expect our business partners to have similar policies which apply to all dealings with, on behalf of, or involving DLA Piper.