Anti-Corruption Policy

AFRICAN COMPASS INTERNATIONAL

(“ACI/the company”)

COMPLIANCE WITH COMPANIES ACT AND OTHER ANTI-CORRUPTION LAWS

Purpose

ACI will conduct its business in compliance with applicable laws and regulations, including the Companies Act (2008), Prevention and Combating of Corrupt Activities Act (2004) and similar anti-bribery laws of other countries such as the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act and laws implementing the Organization for Economic Cooperation and Development (OECD) as well as the UN Convention Against Corruption.

All persons subject to this policy, as noted below, are strictly prohibited from offering, paying, promising or authorizing any bribe, kickback or other thing of value to any “Foreign Official” directly or indirectly through a third party, to secure any contract, concession or other favorable treatment for ACI. In addition, all such persons are required to adhere to ACI’s policies and procedures designed to ensure compliance with these laws.

Scope

This policy applies to all actions performed by business partners on behalf of ACI and to all ACI officers, directors, and full time and part time employees as well as direct representatives. Additionally, this policy will apply to all affiliates and joint ventures controlled by ACI.

All business partners representing ACI (including consultants and agents), who may interact with “foreign officials” on behalf of “the company” shall follow all applicable portions of this policy.