BRIBERY ACT STATEMENT

Updated: Wed 22 May 2019

P&O Ferries is committed to carrying out its business in a fair, honest and open manner. We are committed to zero tolerance of any form of bribery that is carried out by our employees, consultants, contractors, agents and any other persons that are associated with us. We have a Bribery Act policy in place that all persons associated with us must adhere to. This policy prohibits anyone associated with us from offering, promising or giving a bribe or requesting, agreeing to receive or accepting a bribe and puts in place procedures to prevent such offences taking place. We are also committed to ensuring that our suppliers, agents, consultants and contractors throughout our supply chain have or adopt a similar approach. All our suppliers and contractors are required to endorse and adhere to our supplier code of conduct, which includes the above principles. All contracts to be entered into with suppliers and contractors will also contain provisions requiring both parties not to commit an offence under the Bribery Act. The Company shall have the right to terminate any such contracts if this commitment is breached.