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Anti-Bribery & Anti-Corruption

Anti-Bribery / Anti-Corruption Policy

The vast majority of countries have adopted anti-bribery laws and anti-corruption laws. Given that Bankers Cobalt Corp is proposing to transact business in multiple jurisdictions around the world and given our desire to be solid corporate citizens, we recognize that it is critical that we understand and fully comply with the appropriate anti-bribery and anti-corruption legislation.

Many of the Company’s officers, directors, employees, and consultants are either Democratic Republic of Congo, Canadian, US or European citizens and therefore subject to either the Corruption of Foreign Public Officials Act of Canada (“COFPOA”), the US Foreign Corrupt Practices Act of 1977 (“FCPA”), or The Bribery Act (“UK Bribery Act”). Bankers Cobalt is committed to achieving the highest standards of ethical conduct and complying with all applicable laws in the countries where it conducts business including the COFPOA in Canada, the FCPA in the US and UK Bribery Act in the United Kingdom.

COFPOA,FCPA, and UK Bribery Act Policy

It is Bankers Cobalt’s policy to comply fully with all applicable provisions of the COFPOA, the FCPA and, where appropriate the UK Bribery Act. Accordingly, Bankers Cobalt has adopted a policy which prohibits the paying, offering, giving, authorizing, or promising, either directly or indirectly, of anything of value to any government official in order to secure an improper advantage, obtain or retain business, or direct business to any other person or entity.

Through the operation of our compliance program, all officers, directors, employees, agents and consultants must certify their understanding of our policy each year by executing an acknowledgement to that effect. Our Compliance program is administered by our Compliance Officer who reports to the board of directors and ensures that all stakeholders receive the necessary training on compliance as well as any compliance updates. Our guidelines include questionnaires and checklists that are designed to evaluate new projects in terms of their compliance with COFPOA, FCPA, and UK Bribery Act regulations.