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Anti-Corruption and Bribery Policy



1.1 It is our policy to conduct all 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 wherever we operate and implementing and enforcing effective systems to counter bribery.

1.2 We will uphold all laws relevant to countering bribery and corruption. However, we
remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our
conduct both at home and abroad.
1.3 The purpose of this policy is to:
a) Set out our responsibilities, and of those working for us, in observing
and upholding our position on bribery and corruption;
b) Provide information and guidance on how to recognise and deal with
bribery and corruption issues; and
c) Deal with the risk of bribery and corruption in a realistic and
proportionate way.
1.4 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.
1.5 We have identified that the following are potential risks for our business and to
address those risks we have a Gifts and Benefits Policy.
1.6 In this policy, third party means any individual or organisation you meet 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
This policy applies to all individuals working at all levels and grades, including senior
managers, officers, directors, employees (whether permanent, fixed-term or
temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual
workers and agency staff, volunteers, interns, agents, sponsors, or any other person
associated with us, or any of our subsidiaries or their employees, wherever located
(collectively referred to as workers in this policy).
3.1 A bribe is an inappropriate inducement or reward offered, promised or
provided to gain any commercial, contractual, regulatory or personal advantage.
3.2 There are four key offences under the Bribery Act 2010:
a) Bribing another person;
b) Being bribed;
c) Bribery of a foreign official; and
d) Failure of a commercial organisation to prevent bribery.
4.1 This policy does not prohibit normal and appropriate hospitality (given and
received) to or from third parties.
4.2 The giving or receipt of hospitality and gifts is not prohibited, if the following
requirements are met:
a) They are within the scope of the limits set out in the Gifts and Benefits
Policy or if exceeding those limits, they have received prior written
approval from Senior Management & Compliance is notified.
b) It is not made with the intention of influencing a third party to obtain
or retain business or a business advantage, or to reward the provision
or retention of business or a business advantage, or in explicit or
implicit exchange for favours or benefits;
c) It complies with local law;
d) It is given in our name, not in your name;
e) It does not include cash or a cash equivalent (such as gift certificates
or vouchers);
f) It is appropriate in the circumstances. For example, in the UK it is
customary for gifts to be given at Christmas time;
g) Considering the reason for the gift, it is of an appropriate type and
value and given at an appropriate time;
h) It is given openly, not secretly; and
i) Gifts should not be offered to, or accepted from, government officials
or representatives, or politicians or political parties, without the prior
approval the compliance manager.
4.3 We appreciate that the practice of giving business gifts varies between countries
and regions and what may be normal and acceptable in one region may not be in
another. The test to be applied is whether in all the circumstances the gift or hospitality
is reasonable and justifiable. The intention behind the gift should always be
It is not acceptable for you (or someone on your behalf) to:
a) Give, promise to give, or offer, a payment, gift or hospitality with the
expectation or hope that a business advantage will be received, or to
reward a business advantage already given;
b) Give, promise to give, or offer, a payment, gift or hospitality to a
government official, agent or representative to “facilitate” or expedite
a routine procedure;
c) Accept payment from a third party that you know, or suspect is offered
with the expectation that it will obtain a business advantage for them;
d) 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 return;
e) Threaten or retaliate against another worker who has refused to
commit a bribery offence or who has raised concerns under this policy;
f) Engage in any activity that might lead to a breach of this policy.
6.1 We do not make, and will not accept, facilitation payments or “kickbacks” of any
kind. They are not commonly paid in the UK but are common in some other
jurisdictions such as the US where facilitation payments are legal under the Foreign
Corrupt Practices Act 1977.
6.2 If you are asked to make a payment on our behalf, you should always be mindful
of what the payment is for and whether the amount requested is proportionate to the
goods or services provided. You should always ask for a receipt which details the
reason for the payment. If you have any suspicions, concerns or queries regarding a
payment, you should raise these with the compliance manage.
6.3 Kickbacks are typically payments made in return for a business favour or
advantage. All workers must avoid any activity that might lead to, or suggest, that a
facilitation payment or kickback will be made or accepted by us.
We do not make contributions to political parties and 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 Directors together with
compliance being notified.
8.1 You must ensure that you read, understand and comply with this policy.
8.2 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 workers are
required to avoid any activity that might lead to, or suggest, a breach of this policy.
8.3 You must notify the compliance manager as soon as possible if you believe or
suspect that a conflict with this policy has occurred or may occur in the future. For
example, if a client or potential client offers you something to gain a business
advantage with us or indicates to you that a gift or payment is required to secure their
business. Further “red flags” that may indicate bribery or corruption are set out in the
8.4 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.
9.1 We must keep financial records and have appropriate internal controls in place
which will evidence the business reason for making payments to third parties.
9.2 You must declare and keep a written record of all hospitality or gifts accepted or
offered, which will be subject to managerial review.
9.3 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.
9.4 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.
You are encouraged to raise concerns about any issue or suspicion of malpractice at
the earliest possible stage. If you are unsure whether an act constitutes bribery or
corruption, or if you have any other queries, these should be raised with the
compliance manager. Concerns should be reported by following the procedure set out
in our Whistleblowing Policy.
It is important that you tell a director and the compliance manager 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
12.1 Workers who refuse to accept or offer a bribe, or those who raise concerns or
report another’s wrongdoing, are sometimes worried about possible repercussions. 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.
12.2 We are committed to ensuring no one suffers any detrimental treatment as a
result of refusing to take part in bribery or corruption, or because of reporting in good
faith their suspicion that an actual or potential bribery or other corruption offence has
taken place or may take place in the future. 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
the compliance manager immediately. If the matter is not remedied, and you are an
employee, you should raise it formally using our Grievance Procedures (a copy of which
can be found in the Staff Handbook).
13.1 Training on this policy forms part of the induction process for all new workers.
All existing workers will receive regular, relevant training on how to implement and
adhere to this policy.
14.1 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. Senior management takes responsibility for anti-bribery and corruption compliance
within the business and has produced a statement which illustrates senior
management’s commitment to anti-bribery and corruption.
14.2 The compliance manager has primary and day-to-day responsibility for
implementing this policy, and for monitoring its use and effectiveness [and dealing with
any queries on its interpretation]. Management at all levels are responsible for ensuring
those reporting to them are made aware of and understand this policy and are given
adequate and regular training on it.
15.1 The compliance manager will monitor the effectiveness and review the
implementation of this policy, regularly considering its suitability, adequacy and
effectiveness. Any improvements identified will be made as soon as possible. Internal
control systems and procedures will be subject to regular audits to provide assurance
that they are effective in countering bribery and corruption.
15.2 All workers are responsible for the success of this policy and should ensure they
use it to disclose any suspected danger or wrongdoing.
15.3 Workers are invited to comment on this policy and suggest ways in which it might
be improved. Comments, suggestions and queries should be addressed to the
compliance manager.
15.4 This policy does not form part of any employee’s contract of employment and it
may be amended at any time.
Schedule: Potential risk scenarios: “red flags”
The following is a list of possible red flags that may arise during you working for us
and which may raise concerns under various anti-bribery and anti-corruption laws. The
list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them
promptly to the compliance manager:
a) You become aware that a third party engages in, or has been accused of
engaging in, improper business practices;
b) You learn that a third party has a reputation for paying bribes, or requiring
that bribes are paid to them, or has a reputation for having a “special
relationship” with foreign government officials;
c) A third party insists on receiving a commission or fee payment before
committing to sign up to a contract with us, or carrying out a government
function or process for us;
d) A third-party requests payment in cash and/or refuses to sign a formal
commission or fee agreement, or to provide an invoice or receipt for a
payment made;
e) A third party requests an unexpected additional fee or commission to
“facilitate” a service;A third party demands lavish entertainment or gifts
before commencing or continuing contractual negotiations or provision of
f) A third-party requests that a payment is made to “overlook” potential legal
g) You receive an invoice from a third party that appears to be non-standard or
h) A third party insists on the use of side letters or refuses to put terms agreed
in writing;
i) You notice that we have been invoiced for a commission or fee payment that
appears unusually large given the service stated to have been provided;
j) A third party requests or requires the use of an agent, intermediary,
consultant, distributor or supplier that is not typically used by or known to
k) You are offered an unusually generous gift or offered lavish hospitality by a
third party.

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