Statement of Commitment

Sternberg Consulting operates a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.

Scope

This policy applies to all employees, contractors, consultants, agents, and any other party acting on behalf of Sternberg Consulting.

What is Prohibited

The following are strictly prohibited:

• Offering, giving, requesting, or accepting any bribe, kickback, or improper payment
• Using a third party to offer or accept a bribe on our behalf
• Making facilitation payments (unofficial payments to speed up routine government actions)
• Any conduct that could be perceived as an attempt to improperly influence a business decision

Gifts and Hospitality

Reasonable and proportionate gifts and hospitality are permitted where they are:

• Modest in value and not intended to influence a business decision
• Transparent and properly recorded
• In line with the recipient's own organisation's policies

All gifts and hospitality above a nominal value must be approved in advance and recorded.

Third Parties

We carry out appropriate due diligence on third parties we engage, and we expect our business partners, subcontractors, and suppliers to uphold equivalent standards.

Reporting Concerns

Any suspected breach of this policy should be reported immediately through our Whistleblower Policy. All reports are treated confidentially and investigated promptly.

Consequences of Breach

Violations of this policy may result in termination of employment or contract, and may be reported to the relevant authorities.

Review

This policy is reviewed annually. Last reviewed: March 2026.

Contact: info@sternberg-consulting.com