POLICIES

Summary of Due Diligence Guidelines for Mergers, Acquisitions, JVs, Partnerships and other Investments

The purpose of this document is to provide a high level overview of how our due diligence processes are to be applied in mergers, acquisitions, joint ventures, partnerships and other investments.

Our due diligence processes are designed to identify and assess the involvement of potential future partners in bribery, corruption, activities that are prohibited by or subject to international sanctions, unlawful exports, money laundering, modern slavery and any other illegal activity. Such actions run counter to our internal principles and values and would not only reflect badly on our reputation but could also lead to criminal penalties.

We utilize a risk-based approach to compliance due diligence. We encourage early consultation with CCBHC’s Chief Compliance Officer and having the transaction team work closely with the Chief Compliance Officer, external counsel, internal auditors and other appropriate managers to ensure the due diligence process is carried out effectively.

The compliance due diligence process should be started early in the transaction and documented appropriately. CCHBC’s third party due diligence tool should be used to inform the initial risk assessment. A detailed review and report on findings should be prepared with Group Legal and/or external counsel. The due diligence process should be continued after the transaction as additional information comes to hand.

Remember to consult with the Chief Compliance Officer and external legal counsel throughout the process for guidance and to ensure all compliance matters are adequately addressed.

If you need further assistance or a more detailed guidance, please ask Group Legal and M&A Teams.

Updated as of June 30, 2019