Anti-bribery and Corruption Statement

IQE plc and its affiliates (IQE / we) conduct all business honestly, fairly, ethically, free from corruption and in compliance with all applicable laws. IQE has a zero-tolerance approach to bribery and corruption and we require all our employees, directors, consultants, contractors, suppliers, customers and other business partners to comply with all applicable anti-bribery and anti-corruption laws including but not limited to the Foreign Corrupt Practices Act and the Bribery Act 2010.

What is bribery and corruption?

Bribery is a form of corruption in which there is an abuse of entrusted power or position for private gain. Forms of bribery include offering, promising, giving or accepting any financial or other advantage, inducing a person to act improperly in the performance of their functions, or to reward them for acting improperly. It is a criminal offence to offer, promise, give, request, or accept a bribe and individuals found guilty can be punished by imprisonment and/or a fine.

It is never appropriate to:

(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

(b) accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it will provide a business advantage for them or anyone else in return;

(d) threaten or retaliate against another individual who has refused to commit a bribery or corruption offence or who has raised concerns about potential bribery or corruption.

Donations

We do make charitable donations that are legal and ethical under local laws and practices. However, we do not make contributions to political parties. We will also never make facilitation payments (typically small, unofficial payments made to secure or expedite a routine or necessary action, for example by a government official to speed up customs clearances).

Record keeping

IQE keeps financial records and has appropriate internal controls in place which evidences the business reason for making payments to third parties. IQE also keeps a written record of all hospitality and gifts, given or received, in accordance with our Gifts & Hospitality Policy. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers are prepared with strict accuracy and completeness. Accounts are never kept "off-book" to facilitate or conceal improper payments.

Reporting

IQE encourages all of its employees, directors, consultants, contractors, suppliers, customers and other business partners to raise any concerns about issues or suspicion of bribery or corruption at the earliest possible stage. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for or with us. The failure of any employee to comply with IQE’s anti-bribery and corruption policies will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with our consultants, contractors, suppliers, customers and other business partners if they breach our anti-bribery and corruption policies or any applicable anti-bribery and anti-corruption laws.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future.

For further information or to contact us about our anti-bribery and corruption policy or any issues or suspicion of bribery or corruption, please contact our General Counsel & Company Secretary at compliance@iqep.com.

Anti-bribery and Corruption Statement

Responsibility