Anti-bribery Policy

Introduction

The Company values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

• setting out a clear anti-bribery policy,
• establishing and implementing anti-bribery procedures as appropriate,
• communicating this policy and any relevant procedures to employees and to others who will perform services for the Company,
• undertaking appropriate due diligence measures before engaging others to represent the Company in its business dealings,
• monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures that are in place.

Policy

The Company prohibits the offering, giving, solicitation or acceptance of any bribe (whether cash or other inducement)

• to or from any person or company (wherever they are situated and whether they are a public official or body or private person or company),
• by any individual employee, agent or other person or body acting on behalf of the Company,
• in order to gain any commercial, contractual or regulatory advantage for the Company in a way that is unethical, or
• in order to gain any personal advantage (pecuniary or otherwise) for the individual or anyone connected with the individual.

This policy prohibits any inducement that results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action that may not be solely in the interests of the Company or of the person or body employing them or whom they represent.

This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift on a festival or at another special time, providing they are customary in a particular market, are proportionate and are properly recorded. Hospitality or gifts should not be offered, promised or accepted to secure an advantage for the Company or any of its employees or associated persons, or to influence the impartiality of the recipient. It is essential that we keep full and accurate records of all our financial dealings. Transparency is vital; false or misleading records could be very damaging to us. Under money laundering regulations the Company are obliged to report anything which appears to be irregular. Therefore, you must declare and properly record (in writing) all hospitality and gifts given or received. Also, you must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and procedure and properly record the reason for the expenditure. Inevitably, decisions as to what is acceptable may not always be easy. If you are in any doubt as to whether a potential act constitutes bribery, the matter should be referred to Lee Banks the Director before proceeding.

Employees’ responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees and the Company is committed to:

• encouraging employees to be vigilant and to report any suspicion of bribery,
• providing employees with suitable channels of communication and ensuring that sensitive information is treated appropriately,
• investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution,
• taking disciplinary action against any individual(s):
  • involved in bribery, and/or
  • who fails to report any known or suspected bribery, and/or
  • who threatens or commits detrimental or unfair treatment against another person who has either refused to offer or accept a bribe or has raised concerns about possible bribery or corruption.

Any suspicion of bribery should be reported in confidence to Lee Banks the Director who has overall responsibility for bribery prevention.

The Company will regularly monitor the policy and processes in place to guard against and prevent bribery, to make sure processes are being followed, the policy is being adhered to and enforced where necessary, and that the wording and requirements of the policy remain appropriate and fit for purpose.