• Definition
  This Policy should be read as an adjunct to the Company’s Management Policy and Code of Ethics. For the purpose of this policy, bribery and corruption is defined as money or favours offered, given, promised, accepted or solicited in order to influence the judgement or conduct of a private person or public official in a position of trust.

• Filtronic’s Stance on Bribery and Corruption
  Filtronic will not engage in any form of bribery or corruption. This policy applies to all employees of Filtronic and its subsidiaries (“the Group”). All managers in the Group shall at all times comply with the law and they have a duty to inform themselves about the national and international laws relating to their business activities.

• Procedures that should be followed during business transactions

Filtronic’s policy on Bribery and Corruption requires employees:

• Not to offer or make any bribe, unauthorised payment (whether in cash or kind) or inducement of any kind;
• Not to solicit business by offering any bribe, unauthorised payment (whether in cash or kind) or inducement to customers or potential customers;
• Not to accept any kind of bribe or unusual payment or inducement that would not be authorised by the Board of Filtronic in the ordinary course of business;
• To refuse any bribe or unorthodox payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation and to report any such offers;
• Not to make “Facilitisation Payments”. These are payments made to secure or accelerate the performance of a routine action to which the payer has a legal entitlement. Filtronic does not condone such payments being made unless required for medical or safety emergencies in jurisdictions where such payments are considered normal. Where this occurs, a record of any such payment should be kept.
• To maintain a record of all donations to charities and to political parties;
• To report any breaches of this policy, or the Company’s Management Policy and Code of Ethics.

• Reporting Breach
  Any complaints or allegations of breach of this Policy may be reported confidentially through the procedure set out in the Company’s Whistle Blowing Policy.

Hemant Mardia
      Chief Executive Officer, 
      Filtronic plc
      May 2010