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Anti-Bribery & Corruption Policy

1.1 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 business dealings and relationships.

1.2 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

1.3 Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine and face damage to our reputation. We therefore take our legal responsibilities very seriously.

2.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

2.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.

2.3 Corruption is the abuse of entrusted power or position for personal gain.

3.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

3.2 Line management have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.

3.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

3.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to your line management.

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

4.2 The prevention, detection and reporting of bribery and corruption in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

4.3 Specifically, you must not:

4.3.1 give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;

4.3.2 accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;

4.3.3 give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;

4.3.4 accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in returned;

4.3.5 threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

4.3.6 engage in any activity that might lead to a breach of this policy.

4.4 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4.5 If you believe or suspect that a conflict with this policy has occurred, or may occur in the future, you must notify your line manager or report it in accordance with our Whistleblowing Policy as soon as possible.

4.6 You are encouraged to raise concerns about any issue or suspicion of bribery or corruption in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

4.7 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your line manager or report it in accordance with our Whistleblowing Policy as soon as possible.

4.8 If you are unsure about whether a particular act within any tier of our supply chains constitutes bribery or corruption, raise it with your line manager or report it in accordance with our Whistleblowing Policy as soon as possible.

4.9 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that bribery or corruption is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found on the Company Intranet

5.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

5.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

5.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.

5.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

6.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

6.2 Any gifts offered (whether accepted or not) should be notified to the HR department using the form in Appendix 1. The company reserves the right to remove the gift from the employee and for it to be raffled for charity.

6.3 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

7.1 We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donations must be offered or made without the prior approval of your manager.

8.1 Our zero tolerance approach to bribery and corruption in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

9.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

9.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.