Anti-bribery and corruption policy 

1. Purpose   

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.  

2. Policy statement   

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.   

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. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.   

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws in THE United Kingdom in respect of our conduct both at home and abroad.  

 

3. Scope   

3.1 Who is covered by the policy?  

In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.   

This policy applies to all employees (whether permanent, fixed-term or temporary), or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).  

 This policy covers:  

• Bribes;  

• Gifts and hospitality;  

• Facilitation payments;  

• Political contributions;  

• Charitable contributions.  

  

3.2 Bribes  

 Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.  

3.3 Gifts and hospitality  

Employees must not offer or give any gift or hospitality that could be considered a bribe and :   

• which could be regarded as illegal or improper, or which violates the recipient’s policies; or  

• to any public employee or government officials or representatives, or politicians or political parties; or  

• which exceeds £100 in value for  each individual gift or  £200 in value for  each hospitality event (not to exceed a total value of £500 in any financial year), unless approved in writing by the Managing Director.   

Employees may not accept any gift or hospitality from our business partners if:  

 • it exceeds £100 in value for each individual gift or £200 in value for each hospitality event (not to exceed a total of $50000 in any financial year), unless approved in writing by the employee’s manager; or  

• it is in cash; or  

• there is any suggestion that a return favour will be expected or implied.  

If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the manager director and donated to charity.  

3.4 Facilitation payments and kickbacks  

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to.  

Our strict policy is that facilitation payments must not be paid.  

3.5 Political Contributions  

 We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.  

3.6 Charitable contributions  

Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices]. No donation must be offered or made without the prior approval of [the compliance manager.  

All charitable contributions should be publicly disclosed.  

4. Your responsibilities  

You must ensure that you read, understand and comply with this policy.  

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.  

 You must notify the managing director as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.  

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.  

5. Record-keeping  

 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.  

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.   

You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.  

 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.  

7. What to do if you are a victim of bribery or corruption  

It is important that you tell the Managing Director as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.  

9. Training and communication  

Training on this policy forms part of the induction process for all new employees. If the policy changes all existing employees will be adopted. 

 

This policy does not form part of any employee's contract of employment and it may be amended at any time.