Anti-Bribery &
Anti-Corruption Policy

Arcadia Cigars Limited is committed to conducting business with honesty, integrity and transparency. We maintain a zero-tolerance approach to bribery and corruption and expect the same high standards from everyone acting on our behalf.

Our business decisions are based solely on merit, fairness and compliance with applicable laws and regulations.

Purpose

This policy establishes the principles that help prevent bribery and corruption across our business activities and promotes ethical commercial practices.

Our Principles

We are committed to:

• Conducting business fairly and ethically.
• Rejecting all forms of bribery and corruption.
• Complying with applicable anti-bribery legislation.
• Promoting transparency and accountability.
• Maintaining accurate business records.
• Encouraging ethical decision-making at every level of the business.

Prohibited Conduct

Arcadia Cigars does not permit:

• Offering or accepting bribes.
• Facilitation payments.
• Kickbacks or secret commissions.
• Fraudulent or deceptive business practices.
• Improper gifts or hospitality intended to influence business decisions.
• Any conduct that could create an actual or perceived conflict of interest.

Gifts and Hospitality

Reasonable business hospitality may be accepted or offered where lawful, proportionate and appropriate. Gifts or hospitality must never influence, or appear to influence, business decisions.

Third Parties

We expect suppliers, consultants, contractors and business partners to operate with the same ethical standards and comply with applicable anti-bribery laws.

Reporting Concerns

Anyone who becomes aware of suspected bribery, corruption or unethical conduct involving Arcadia Cigars is encouraged to report the matter promptly. Concerns will be reviewed fairly and, where appropriate, confidentially.

Compliance

Failure to comply with this policy may result in appropriate action in accordance with applicable laws, contractual obligations or company procedures.

Review

This policy is reviewed periodically to ensure it remains effective and reflects current legal and ethical standards.