Anti-Bribery Policy

Introduction

The Stobart Group is committed to conducting its business around the world with the highest degree of integrity. This commitment includes a zero tolerance approach towards all forms of bribery and corruption.

This Code of Conduct has been formally approved by the Group’s Board of Directors and extends to all of the Group’s business dealings and transactions in all countries around the world in which any member of the Group, its associates, joint venture partners or agents operate.

It is a mandatory requirement of the Group that all people who perform services on behalf of the Group including directors, officers, employees, joint venture partners, agents, advisors, customers and suppliers comply with this Code of Conduct and, you should ensure that you are fully familiar with its contents, refreshing your memory as necessary from time to time. The Group has appointed a Compliance Officer (whose contact details are set out in Section 5 below) to whom you can address any queries or concerns.

Engaging in bribery and corruption is unlawful and any employee, director or officer found to have breached this Code of Conduct will be liable to disciplinary action which may result in dismissal or other serious sanctions. Breaches of this Code of Conduct by customers, suppliers, joint venture partners or third party contractors and advisors to the Group may result in immediate termination for breach of all contracts with the Group.

Further, engaging in bribery and corruption whether at home or abroad will constitute a criminal offence which will expose both the Group and you personally to serious criminal sanctions including, the risk of imprisonment.

All of us share a responsibility to ensure compliance with this Code of Conduct and, should you become aware that any person acting or purporting to act on the behalf of the Group may have committed an act of bribery or corruption, then you must report your concerns immediately to the Compliance Officer. In addition to this Code of Conduct, the Group operates a strict Whistleblowing Policy and you can be assured that reporting any concerns will not result in you receiving any negative or retaliatory treatment from the Group.

I know that everyone within the Group shares the commitment of the Board of Directors to ensuring that the highest standards of business integrity are maintained and that I can count on you for your full support.

Thank you.

Andrew Tinkler
Chief Executive Officer
January 2012

Note: To view the full policy please see related document to the right.