Anti-Bribery & Anti-Corruption Policy

Zero-tolerance statement

Letlou Energy (Pty) Ltd prohibits bribery, kickbacks, corruption, or any improper payments — directly or indirectly — to government officials, private sector partners, or any third parties in connection with our business activities. We will not tolerate any form of bribery or corruption by any person acting on our behalf, including employees, contractors, agents, or business partners.

This zero-tolerance policy applies to all business dealings, regardless of local custom or practice, and extends to any jurisdiction in which we operate or seek to do business.

Scope and application

This policy applies to:

• All directors, officers, and employees of Letlou Energy (Pty) Ltd, regardless of seniority or location.
• Contractors, consultants, agents, and representatives acting on behalf of Letlou Energy.
• Business partners, joint venture partners, and suppliers where Letlou Energy has operational control or influence.

All persons covered by this policy must read, understand, and comply with its provisions. Violations may result in disciplinary action, termination of employment or contract, and referral to relevant law enforcement authorities.

What is prohibited

Under this policy, the following conduct is strictly prohibited:

• Bribery: offering, promising, giving, requesting, or accepting any financial or other advantage to influence a business decision, obtain or retain business, or secure an improper advantage.
• Corrupt conduct: any act that amounts to corruption under South Africa's Prevention and Combating of Corrupt Activities Act (POCA) or any equivalent foreign law (including the UK Bribery Act and the US Foreign Corrupt Practices Act).
• Kickbacks: undisclosed payments or benefits provided to a person in return for favourable treatment in a business transaction.
• Improper influence: any attempt to improperly influence a public official, client, supplier, or any other person in connection with Letlou Energy's business.

Gifts & hospitality

Modest, proportionate, and infrequent gifts or hospitality may be acceptable where they:

• Are transparent, properly recorded, and given in the ordinary course of business.
• Are not cash or cash equivalents (e.g. vouchers, loans, shares).
• Are not offered or accepted during a tender or procurement process.
• Do not create an obligation or expectation of preferential treatment.

Gift and hospitality limits:

• Any single item valued over ZAR 500 (or equivalent in local currency) must be declared to and approved by management.
• No single gift or hospitality event may exceed ZAR 2,500 (or equivalent) without prior written approval from a director.
• Any gift or hospitality accepted from a third party must be recorded in writing and retained on file by the principal or the relevant engaged resource. A written record noting the giver, nature, estimated value, and date is sufficient.

The following are never permitted:

• Cash gifts or cash equivalents (including store vouchers, cryptocurrencies, or prepaid cards).
• Luxury travel, accommodation, or entertainment that could reasonably be seen as excessive.
• Gifts or hospitality offered to public officials without prior legal advice.

Facilitation payments

Facilitation payments — small, unofficial payments made to secure or expedite routine government actions (e.g., processing permits, issuing licences) — are prohibited under this policy, even where local custom may suggest otherwise.

If you are asked to make a facilitation payment, you must refuse and immediately report the request through the channels set out in Section 8 below.

Political contributions & charitable donations

Letlou Energy does not make contributions to political parties, candidates, or political organisations. Any such contribution is prohibited. Given Letlou's current structure as a sole-director practice, no political contribution may be made under any circumstances without written documentation of the rationale and prior notification to the company's legal advisor.

Charitable donations are permitted only where they:

• Are made for genuine philanthropic purposes, not to obtain a business advantage.
• Are properly documented and made to legitimate registered non-profit organisations.
• Are not made at the request of a government official or client to influence a decision.

Third parties, agents & partners

Letlou Energy may be held liable for bribes or corrupt acts committed by third parties acting on our behalf. Accordingly:

• All agents, consultants, and business partners must undergo reasonable due diligence before engagement.
• All contracts with third parties must include specific anti-bribery and anti-corruption provisions.
• Letlou Energy reserves the right to audit third parties to ensure compliance with this policy.

If you become aware that a third party acting on Letlou Energy's behalf has engaged in or proposed any corrupt conduct, you must report it immediately.

Reporting violations

Any person who suspects, believes, or becomes aware of a potential breach of this policy — whether by an employee, contractor, agent, partner, or third party — has a duty to report it.

You may report suspected violations confidentially through the following channels:

• Direct report: to your line manager or any director of Letlou Energy.
• Confidential email: legal@letlou.co.za
• Anonymous channel: a confidential voicemail service is available by contacting +27 78-4944-034 and asking for the compliance line (you are not required to give your name).

Letlou Energy strictly prohibits retaliation against any person who makes a good-faith report of suspected misconduct. Retaliation will result in disciplinary action, up to and including dismissal. Any person who makes a good-faith disclosure is additionally protected under the Protected Disclosures Act 26 of 2000 (as amended by Act 5 of 2017), which confers statutory protection on employees and workers who report criminal or irregular conduct in the workplace.

Consequences of non-compliance

Violations of this policy are treated with the utmost seriousness. Consequences may include:

• For employees: disciplinary action, up to and including dismissal and potential criminal prosecution.
• For contractors / agents: immediate termination of contract and referral to relevant authorities.
• For third parties: termination of business relationship and reporting to law enforcement.

Bribery and corruption are criminal offences in South Africa under the Prevention and Combating of Corrupt Activities Act (POCA). Conviction may result in substantial fines and imprisonment.

Training & awareness

Letlou Energy is committed to ensuring that every person engaged to act on its behalf — whether as a sub-contractor, consultant, or agent — receives a copy of this policy before commencing work and confirms in writing that they have read and understood it. The principal reviews this policy annually and updates it whenever relevant law or business circumstances change.

Policy review

This policy is reviewed annually by the director of Letlou Energy (Pty) Ltd, or more frequently if required by changes in law or business circumstances. The "Last updated" date at the top of this page reflects the most recent revision.

Contact

For questions, concerns, or to report a suspected violation (including confidentially), please contact:

Anonymous reports may be made using the confidential voicemail service at the same phone number.