The Board of Directors holds primary responsibility for implementing this policy and for reporting on its compliance to the Board of Directors. The Board of Directors nominates the Chief Executive Officer (CEO) to be the care-taker of this policy, who in turn has delegated the responsibilities of managing compliance with this policy to AAC. ’s Compliance Officer.

With the assistance of AAC. ’s Compliance Officer, all offices of AAC. and its subsidiaries must estab- lish appropriate mechanisms and procedures within their operations to prevent, detect, investigate and report any violations of AAC.’s Anti-Corruption and Anti-Bribery Policy.