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Corbis Entertainment

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Anti-bribery and Corruption Policy

WSM’s Anti-bribery and Corruption Policy

Introduction

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings wherever we operate. We are committed to implementing and enforcing effective measures to counter bribery.

The policy

WSM prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual employee, agent or other person or body acting on WSM's behalf in order to gain any commercial, contractual or regulatory advantage for WSM in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

This policy is not meant to prohibit the following activities, provided they are customary, proportionate and properly recorded:

Responsibility

This policy is applicable to all directors and employees of WSM. The prevention, detection and reporting of bribery is the responsibility of all WSM's employees. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained through whistleblowing procedures. WSM will investigate seriously any actual or suspected breach of this policy, or the spirit of this policy. Employees may be subject to disciplinary action.

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