Anti-Bribery and Anti-Corruption Policy

Scope and accountability

This policy applies to directors, employees, agents and contractors acting for PILORA Resources Ltd. Suppliers and other business partners are expected to follow equivalent standards in dealings connected to PILORA. The Managing Director is responsible for oversight, explaining these requirements and ensuring concerns receive a fair review. No commercial target justifies corrupt conduct.

Prohibited conduct

Do not offer, promise, give, request or accept a bribe, kickback or other improper advantage, directly or through another person. This includes non-cash benefits, employment favours and disguised commissions. The prohibition covers public officials and private businesses. Facilitation payments to speed up routine official actions are prohibited. Refuse improper requests and report them. If personal safety is threatened, prioritise safety and promptly report the circumstances and any payment accurately.

Gifts, hospitality and conflicts

Gifts or hospitality must have a legitimate business purpose, be modest, proportionate and openly recorded. They must never influence, or appear intended to influence, procurement, contract awards, inspections or other decisions. Cash and cash equivalents are prohibited. Obtain prior Managing Director approval and follow the recipient's rules. Decline benefits that cannot meet these conditions.

Declare personal, family or financial interests that could affect impartial decisions and withdraw where needed. Nobody may approve their own gift, expense or conflicted transaction. Where the Managing Director benefits or is otherwise conflicted, another unconflicted authorised person must provide written approval beforehand. If suitable approval cannot be arranged, do not proceed.

Partners, payments and records

Before appointing a supplier, agent or intermediary, make checks proportionate to the work and risk. Confirm identity, ownership where relevant, capability, reputation, service scope and payment arrangements. Investigate unexplained commissions, requests for unrelated accounts or vague services before proceeding. Communicate this policy and include suitable contractual expectations.

Record payments, gifts, expenses and services accurately with supporting documents. No secret funds, false invoices or misleading descriptions are permitted. Donations or sponsorships must never disguise an improper advantage.

Raise a confidential concern

Report suspected misconduct to info@piloraresourcesltd.com (or piloraresourcesltd@gmail.com as backup) using the subject 'Confidential concern'. Describe the concern and preserve relevant records. The Managing Director will arrange proportionate, impartial handling and seek independent assistance where a conflict could compromise review. Information will be shared only as needed to respond or meet legal duties.

Retaliation against anyone who honestly raises a concern, refuses a bribe or assists a review is prohibited, even if the concern is not substantiated. People remain free to seek independent advice or contact competent authorities.

Action and review

Confirmed breaches may lead to corrective measures, disciplinary or contractual action and referral to authorities where appropriate. The Managing Director will review this policy at least annually and after significant concerns or changes in business risks or requirements.