fastjet’s Anti Bribery and Corruption Policy

1 Policy statement
1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-
tolerance approach to bribery and corruption and are committed to acting professionally,
fairly and with integrity in all our business dealings and relationships wherever we operate
and implementing and enforcing effective systems to counter bribery.
1.2 We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in
which we operate. However, we remain bound by the laws of the UK, including the Bribery
Act 2010, in respect of our conduct both at home and abroad.
1.3 The purpose of this policy is to:
1.3.1 set out our responsibilities, and of those working for us, in observing and upholding
our position on bribery and corruption; and
1.3.2 provide information and guidance to those working for us on how to recognise and
deal with bribery and corruption issues.
1.4 Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if
we are found to have taken part in corruption we could face an unlimited fine, be excluded
from tendering for public contracts and face damage to our reputation. We therefore take
our legal responsibilities very seriously.
1.5 We have identified that the following are particular risks for our business: Country risk,
sectoral risk, transaction risk, business opportunity risk, business partnership risk and
hospitality risk. To address those risks the company policy has been defined and circulated to
all key staff.
1.6 In this policy, "third party" means any individual or organisation you come into contact with
during the course of your work for us, and includes actual and potential clients, customers,
suppliers of services, distributors, business contacts, agents, advisers, and government and
public bodies, including their advisors, representatives and officials, politicians and political
parties.

2 Who is covered by this policy?

This policy applies to all individuals working at all levels and grades, including senior
managers, officers, directors, employees (whether permanent, fixed-term or temporary),
consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency
staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of
our subsidiaries or their employees, wherever located (collectively referred to as "workers" in
this policy).

3 What is Bribery?
3.1 A bribe is an inducement or reward offered, promised or provided in order to gain any
commercial, contractual, regulatory or personal advantage. Examples include:
3.2 Offering a bribe

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 You offer a potential client tickets to a major sporting event, but only if they agree to do
business with us.
This would be an offence as you are making the offer to gain a commercial and contractual
advantage. We may also be found to have committed an offence because the offer has been
made to obtain business for us. It may also be an offence for the potential client to accept
your offer.
3.3 Receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return they expect you to use
your influence in our organisation to ensure we continue to do business with them.
It is an offence for a supplier to make such an offer. It would be an offence for you to accept
the offer as you would be doing so to gain a personal advantage.
3.4 Bribing a foreign official
You arrange for the business to pay an additional payment to a foreign official to speed up an
administrative process.
The offence of bribing a foreign public official has been committed as soon as the offer is
made. This is because it is made to gain a business advantage for us. We may also be found to
have committed an offence.

4 Gifts and Hospitality

4.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or
from third parties.
4.2 The giving or receipt of gifts is not prohibited, if the following requirements are met:
4.2.1 it is not made with the intention of influencing a third party to obtain or retain
business or a business advantage, or to reward the provision or retention of
business or a business advantage, or in explicit or implicit exchange for favours or
benefits;
4.2.2 it complies with local law;
4.2.3 it is given in our name, not in your name;
4.2.4 it does not include cash or a cash equivalent (such as gift certificates or vouchers);
4.2.5 it is appropriate in the circumstances. For example, in the UK it is customary for
small gifts to be given at Christmas time;
4.2.6 taking into account the reason for the gift, it is of an appropriate type and value and
given at an appropriate time;
4.2.7 it is given openly, not secretly; and
4.2.8 gifts should not be offered to, or accepted from, government officials or
representatives, or politicians or political parties, without the prior approval of
fastjet Plc’s Chief Financial Officer.
4.3 We appreciate that the practice of giving business gifts varies between countries and regions
and what may be normal and acceptable in one region may not be in another.

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4.4 The test to be applied is whether in all the circumstances the gift or hospitality is reasonable
and justifiable. The intention behind the gift should always be considered.

5 What is not acceptable?

5.1 It is not acceptable for you (or someone on your behalf) to:
5.1.1 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;
5.1.2 give, promise to give, or offer, a payment, gift or hospitality to a government official,
agent or representative to "facilitate" or expedite a routine procedure;
5.1.3 accept payment from a third party that you know or suspect is offered with the
expectation that it will obtain a business advantage for them;
5.1.4 accept a gift or hospitality from a third party if you know or suspect that it is offered
or provided with an expectation that a business advantage will be provided by us in
return;
5.1.5 threaten or retaliate against another worker who has refused to commit a bribery
offence or who has raised concerns under this policy; or
5.1.6 engage in any activity that might lead to a breach of this policy.

6 Facilitation payments and kickbacks

6.1 We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.
Facilitation payments are typically small, unofficial payments made to secure or expedite a
routine government action by a government official. They are not commonly paid in the UK,
but are common in some other jurisdictions in which we operate.
6.2 If you are asked to make a payment on our behalf, you should always be mindful of what the
payment is for and whether the amount requested is proportionate to the goods or services
provided. You should always ask for a receipt which details the reason for the payment. If you
have any suspicions, concerns or queries regarding a payment, you should raise these with
fastjet Plc’s Chief Financial Officer.
6.3 Kickbacks are typically payments made in return for a business favour or advantage. All
workers must avoid any activity that might lead to, or suggest, that a facilitation payment or
kickback will be made or accepted by us.

7 Donations
We do not make contributions to political parties. We only make charitable donations that
are legal and ethical under local laws and practices. No donation must be offered or made
without the prior approval of fastjet Plc’s Chief Financial Officer.

8 Your responsibilities
8.1 You must ensure that you read, understand and comply with this policy.

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8.2 The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for us or under our control. All workers are required to
avoid any activity that might lead to, or suggest, a breach of this policy.
8.3 You must notify fastjet Plc’s Chief Financial Officer as soon as possible if you believe or
suspect that a conflict with this policy has occurred, or may occur in the future. For example,
if a client or potential client offers you something to gain a business advantage with us, or
indicates to you that a gift or payment is required to secure their business. Further "red flags"
that may indicate bribery or corruption are set out in Schedule 1.
8.4 Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for gross misconduct. We reserve our right to terminate our contractual
relationship with other workers if they breach this policy.

9 Record-keeping
9.1 We must keep financial records and have appropriate internal controls in place which will
evidence the business reason for making payments to third parties.
9.2 You must declare and keep a written record of all hospitality or gifts accepted or offered,
which will be subject to managerial review.
9.3 You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third
parties are submitted in accordance with our expenses policy and specifically record the
reason for the expenditure.
9.4 All accounts, invoices, memoranda and other documents and records relating to dealings
with third parties, such as clients, suppliers and business contacts, should be prepared and
maintained with strict accuracy and completeness. No accounts must be kept "off-book" to
facilitate or conceal improper payments.

10 How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the
earliest possible stage. If you are unsure whether a particular act constitutes bribery or
corruption, or if you have any other queries, these should be raised with fastjet Plc’s Chief
Financial Officer. Concerns should be reported by following the procedure set out in our
Whistleblowing Policy.

11 What to do if you are a victim of bribery or corruption

It is important that you tell fastjet Plc’s Chief Financial Officer as soon as possible if you are
offered a bribe by a third party, are asked to make one, suspect that this may happen in the
future, or believe that you are a victim of another form of unlawful activity.

12 Protection
12.1 Workers who refuse to accept or offer a bribe, or those who raise concerns or report
another's wrongdoing, are sometimes worried about possible repercussions. We aim to
encourage openness and will support anyone who raises genuine concerns in good faith
under this policy, even if they turn out to be mistaken.

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12.2 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. Detrimental treatment includes dismissal, disciplinary action,
threats or other unfavourable treatment connected with raising a concern. If you believe that
you have suffered any such treatment, you should inform fastjet Plc’s Chief Financial Officer
immediately. If the matter is not remedied, and you are an employee, you should raise it
formally using our Grievance Procedure.

13 Training and communication

13.1 Training on this policy forms part of the induction process for all new workers. All existing
workers will receive regular, relevant training on how to implement and adhere to this policy.
13.2 Our zero-tolerance approach to bribery and corruption must be communicated to all
suppliers, contractors and business partners at the outset of our business relationship with
them and as appropriate thereafter.

14 Who is responsible for the policy?

14.1 The board of directors has overall responsibility for ensuring this policy complies with our
legal and ethical obligations, and that all those under our control comply with it.
14.2 fastjet Plc’s Chief Financial Officer has primary and day-to-day responsibility for implementing
this policy, and for monitoring its use and effectiveness and dealing with any queries on its
interpretation. Management at all levels are responsible for ensuring those reporting to them
are made aware of and understand this policy and are given adequate and regular training on
it.

15 Monitoring and review

15.1 fastjet Plc’s Chief Financial Officer will monitor the effectiveness and review the
implementation of this policy, regularly considering its suitability, adequacy and
effectiveness. Any improvements identified will be made as soon as possible. Internal control
systems and procedures will be subject to regular audits by the Audit Committee to provide
assurance that they are effective in countering bribery and corruption.
15.2 All workers are responsible for the success of this policy and should ensure they use it to
disclose any suspected danger or wrongdoing.
15.3 Workers are invited to comment on this policy and suggest ways in which it might be
improved. Comments, suggestions and queries should be addressed to fastjet Plc’s Chief
Financial Officer.
15.4 This policy does not form part of any employee's contract of employment and it may be
amended at any time.

16 Potential risk scenarios: "red flags"

16.1 The following is a list of possible red flags that may arise during the course of you working for
us and which may raise concerns under various anti-bribery and anti-corruption laws.
16.2 The list is not intended to be exhaustive and is for illustrative purposes only.

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16.3 If you encounter any of these red flags while working for us, you must report them promptly
to fastjet Plc’s Chief Financial Officer using the procedure set out in the whistleblowing policy:
16.3.1 you become aware that a third party engages in, or has been accused of engaging
in, improper business practices;
16.3.2 you learn that a third party has a reputation for paying bribes, or requiring that
bribes are paid to them, or has a reputation for having a "special relationship" with
foreign government officials;
16.3.3 a third party insists on receiving a commission or fee payment before committing to
sign up to a contract with us, or carrying out a government function or process for
us;
16.3.4 a third party requests payment in cash and/or refuses to sign a formal commission
or fee agreement, or to provide an invoice or receipt for a payment made;
16.3.5 a third party requests that payment is made to a country or geographic location
different from where the third party resides or conducts business;
16.3.6 a third party requests an unexpected additional fee or commission to "facilitate" a
service;
16.3.7 a third party demands lavish entertainment or gifts before commencing or
continuing contractual negotiations or provision of services;
16.3.8 a third party requests that a payment is made to "overlook" potential legal
violations;
16.3.9 a third party requests that you provide employment or some other advantage to a
friend or relative;
16.3.10 you receive an invoice from a third party that appears to be non-standard or
customised;
16.3.11 a third party insists on the use of side letters or refuses to put terms agreed in
writing;
16.3.12 you notice that we have been invoiced for a commission or fee payment that
appears large given the service stated to have been provided;
16.3.13 a third party requests or requires the use of an agent, intermediary, consultant,
distributor or supplier that is not typically used by or known to us; or
16.3.14 you are offered an unusually generous gift or offered lavish hospitality by a third
party.

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