Anti-Bribery and Corruption Policy

‍

1. Introduction

Darling is committed to conducting its business with the highest standards of ethics and integrity. This Anti-Bribery & Corruption (“ABC”) Policy outlines our zero-tolerance approach to bribery and corruption, ensuring compliance with all applicable laws and regulations. This policy applies to all employees, contractors, agents, subsidiaries, and any other individuals or entities acting on behalf of Darling.

‍

2. Policy Overview

Darling strictly prohibits bribery, corruption, or any other unethical conduct in all business dealings, whether with public officials, private sector partners, or third parties. This policy provides guidance on how to identify, prevent, and report bribery and corruption within the company.

‍

3. Definitions

• Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of an individual in a position of power or trust.
• Corruption: Abuse of entrusted power for private gain, including bribery, extortion, fraud, and embezzlement.
• Facilitation Payments: Small payments made to expedite routine governmental actions, which are strictly prohibited under this policy.

‍

4. Guiding Principles

4.1 Compliance with Laws

Darling and its employees must comply with all applicable anti-bribery and anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other relevant local laws.

4.2 Prohibition of Bribery and Corruption

Darling strictly prohibits:

• Offering, promising, giving, or authorizing bribes, either directly or indirectly.
• Soliciting, accepting, or receiving bribes from any individual or entity.
• Engaging in any form of corrupt activity, including facilitation payments.

4.3 Third-Party Relationships

Darling requires that all third parties acting on its behalf, including suppliers, agents, consultants, and partners, adhere to the same standards of anti-bribery and anti-corruption. Due diligence must be conducted before engaging with third parties, and ongoing monitoring is required to ensure compliance.

4.4 Gifts, Hospitality, and Expenses

Gifts and hospitality must never be offered or accepted with the intention of influencing business decisions. All gifts, hospitality, and expenses must be:

• Reasonable and proportionate.
• Transparent and accurately recorded in Darling’s financial records.
• Pre-approved by senior management when exceeding a certain value (as specified in Darling’s internal guidelines).

‍

5. Responsibilities

5.1 Employees

All employees are responsible for understanding and complying with this policy. Employees must not engage in any activities that could lead to a breach of this policy. They are also required to report any suspicions of bribery or corruption through the appropriate channels.

5.2 Management

Darling’s management team is responsible for implementing and enforcing this policy. They must ensure that all employees receive regular training on anti-bribery and anti-corruption practices.

5.3 Legal, Risk, and Compliance Team

The Legal, Risk, and Compliance (LRC) team is responsible for overseeing compliance with this policy, conducting risk assessments, and providing guidance on anti-bribery and anti-corruption matters. The compliance team can be reached at support@darlinganalytics.ai for any guidance or clarification regarding anti-bribery and anti-corruption matters.

‍

6. Reporting and Whistleblowing

6.1 Reporting

Employees and third parties are encouraged to report any concerns related to bribery or corruption. Reports can be made anonymously if preferred, and Darling is committed to protecting whistleblowers from retaliation.

6.2 Investigation

All reports of bribery or corruption will be promptly and thoroughly investigated. Darling will take appropriate action based on the findings of the investigation, which may include disciplinary measures, termination of contracts, or legal action.

‍

7. Record-Keeping

Darling requires accurate and complete record-keeping to demonstrate compliance with anti-bribery and anti-corruption laws. All financial transactions must be recorded transparently, with sufficient detail to allow for audits and reviews.

‍

8. Training and Awareness

Darling provides regular training on anti-bribery and anti-corruption for all employees, particularly those in roles that may be exposed to bribery risks. Training includes:

• Understanding the types of bribery and corruption.
• Identifying red flags and risk areas.
• Procedures for reporting concerns.

‍

9. Monitoring and Review

This policy will be reviewed periodically to ensure its effectiveness and relevance. The LRC team will monitor compliance with this policy and report any significant issues to senior management and the Board of Directors.

‍

10. Consequences of Non-Compliance

Employees who violate this policy will face disciplinary action, which may include termination of employment. In addition, Darling may terminate relationships with third parties who fail to comply with this policy. Violations may also result in legal action against individuals or entities involved.

‍