Accent Resources N.L. (ACS or the Company) is committed to conducting its business in accordance with all applicable laws and regulations and in accordance with the highest standards of ethical behaviour.

ACS prohibits any activity that seeks to bribe or otherwise improperly influence a Public Official in any country to act (or omit to act) in a way that differs from that official's proper duties, obligations and standards of conduct.

ACS also prohibits any activity that seeks to bribe or otherwise improperly influence any other individual or company in the public or private sector to act (or omit to act) in a way that differs from the proper performance of their role or function.

SCOPE

This Policy applies to all directors, officers and employees of ACS, and all subsidiaries, contractors, secondees, consultants, agents and other individuals or entities that are effectively controlled by ACS or act on its behalf, either directly or indirectly (ACS Personnel).

It is the responsibility of all ACS Personnel to understand and comply with this Policy and to follow the reporting requirements set out in this Policy.

Any queries regarding how to apply this Policy to a particular event or circumstance should be directed to your manager or the Company Secretary.

Overall responsibility for this Policy lies with the Board of Directors.

THE LAWS APPLY IN AUSTRALIA AND OVERSEAS

ACS is subject to a range of legal obligations with bribery and corruption within Australia, including the Australian Criminal Code Act 1995 (Cth). In some instances, ACS may also be subject to related international law for bribery and corruption purposes, such as the US Foreign Corrupt Practices Act and the UK Bribery Act 2010, which have extra-territorial reach. This means that, for example, under Australian law an Australian citizen may be prosecuted in Australia even where the relevant activity occurred entirely overseas. These laws apply to both the Company and ACS Personnel.

PROHIBITIONS ON BRIBERY

ACS prohibits the giving, offering, promising, authorising, accepting or requesting of a bribe. Bribery involves improperly giving, offering or promising a benefit (monetary or otherwise) to a person to: Obtain or retain a business advantage that is not legitimately due; or Induce or reward the improper exercise of the duties or functions of a Public Official or a person within the public or private sector.

The benefit can be direct or indirect.

It is irrelevant whether the payee or recipient of the act of bribery works in the public or private sector. The relevant laws apply to bribery of Public Officials as well as bribery in relation to any commercial transaction in the private sector.

It is irrelevant whether the bribe is accepted or ultimately paid - merely offering the bribe will be a contravention of this Policy and will usually be sufficient for an offence to be committed. Liability may arise notwithstanding that the benefit is given or offered indirectly to the person who is sought to be influenced, for instance to a business associate or family member.

In addition to the above, ACS Personnel should check whether any Public Officials ACS is dealing with have their own Code of Conduct or are subject to local laws relating to acceptance of hospitality and gifts.

As an example, the Australian Public Service Code of Conduct and Values set out in section 10 of the Public Service Act 1999, as well as individual agency guidelines, generally provide that acceptance of gifts or hospitality will not be appropriate in the majority of circumstances, including where the provider of the gift or hospitality is involved in a tender process with the agency or is the subject of a decision within the discretionary power or substantial influence of the government employee concerned. However, outside such circumstances, the guidelines do permit some acceptance of hospitality in circumstances where that hospitality may genuinely assist the agency to develop and maintain constructive relationships with stakeholders.

PROHIBITION ON FACILITATION PAYMENTS

ACS prohibits the making of facilitation payments.

Facilitation payments are minor unofficial payments made to Public Officials either directly or indirectly to expedite or secure the performance of routine government action (for example, to facilitate the expedition of applications for visas, licences, etc).

Facilitation payments are prohibited under the law and under this Policy.

PROHIBITION ON SECRET COMMISSIONS

ACS prohibits the paying or receiving of secret commissions or payments to any person or entity.

Secret commissions or payments occur where a commission from a third party is taken or solicited without disclosing that commission to their principal. The secret commission is given as an inducement to that person to use their position to influence the conduct of their principal's business. This would include, for instance, making a payment to an employee or agent of a customer of ACS, where that employee or agent does not disclose the payment to the customer, in return for obtaining a commercial advantage to ACS from that customer.

PROHIBITION ON IMPROPER GIFTS AND ENTERTAINMENT

ACS prohibits the giving or receiving of gifts, entertainment or sponsored travel in circumstances which could be considered to give rise to undue influence or a direct conflict of interest. Gifts, entertainment and sponsored travel must not be provided or accepted unless in accordance with this Policy.

The practice of giving corporate gifts and arranging corporate hospitality varies between countries, regions and industries, and what may be common and appropriate in one place may not be in another. ACS Personnel must approach this issue carefully and conservatively. If you are uncertain about the potential issue in giving or receiving gifts, entertainment or travel you should consult with the Company Secretary.

PROHIBITION ON MONEY LAUNDERING

ACS prohibits any forms of money laundering in connection with its business activities.

Money laundering is the process by which a person or entity conceals the existence of an illegal source of income and then disguises that income to make it appear legitimate

Use by ACS of proceeds of illegal activity can give rise to liability to ACS and/or to individuals involved in that conduct. If you become aware of any transaction that you think might involve the payment or receipt of proceeds of any unlawful activity you should contact the Company Secretary immediately.

PROHIBITION ON BREACH OF SANCTIONS

ACS prohibits the making of any payment or engaging in any transaction that is in breach of any Sanctions Law. This includes: The providing or receiving of any payment, other benefit, goods or service, directly or indirectly, to or from any individual or entity that is subject to a Sanctions Law; Any activity in connection with a designated country, where that activity is prohibited by a Sanctions Law; Encouraging, permitting or otherwise allowing any person or entity acting on behalf of ACS to engage in any conduct or transaction that is prohibited by a Sanctions Law and Any measure intended to circumvent prohibitions imposed under a Sanctions Law.

ACS also prohibits engaging or continuing to engage with a third party where it is expected or likely that the nature of the engagement may breach a Sanctions Law. Sanctions are subject to frequent change. If you are uncertain whether a Sanctions Law applies in a particular situation you should consult with the Company Secretary.

PAYMENTS TO PROTECT YOUR SAFETY

Payments to protect your safety are permitted. When ACS Personnel face demands that involve imminent explicit or implicit threats to personal safety, they may make a payment which would otherwise be prohibited under this Policy, in which case the individual must notify their manager and the Company Secretary, as soon as reasonably practicable. Any such payment must be promptly recorded (including the amount, to whom it was made and the circumstances in which it was made).

Contact:

Tel: +61 3 9670 0888

(C) 2020 Electronic News Publishing, source ENP Newswire