Bribery Prevention Policy

The Company complies fully with The Bribery Act 2010 and recognises that bribery is a criminal offence. This policy has been put in place in order to make all employees aware of what constitutes bribery and that it will not be tolerated.

The Company will not tolerate any form of bribery by, or of, its employees or associated persons acting on its behalf. The Company is committed to carrying out its business fairly, honestly and openly, and adopts a zero tolerance policy towards bribery whilst implementing effective measures to prevent, monitor and eliminate bribery.

Associated persons include volunteers, temporary workers, contractors, consultants, agents and subsidiaries acting for or on behalf of the Company.

It is an offence for employees or any associated persons to offer, promise or give a financial or other advantage to another person in the following circumstances:

• Where the employee or associated person intends the advantage to bring about the improper performance by another person of a relevant function or activity or to reward such improper performance; or
• Where the employee or associated person knows or believes that the acceptance of the advantage offered, promised or given in it constitutes the improper performance of a relevant function or activity.
• Improper performance means performance which amounts to a breach of an expectation that a person will act in good faith, impartially, or in accordance with a position of trust.

The offence applies to bribery relating to any function of a public nature, connected with a business, performed in the course of a person’s employment or performed on behalf of a company or another body of persons.

Employees and associated persons must not offer, promise or give a financial or other advantage to a foreign public official with the intention of influencing the official in the performance of their official functions with the intention to obtain or retain business or an advantage in the conduct of business by doing so. However, the offence is not committed where the official is permitted or required by the applicable written law to be influenced by the advantage.

If any employees or associated persons have reasonable belief that an act of bribery is, has or could potentially take place they should refer to the Whistle blowing policy set out in our handbook. They should then raise their concerns formally at the earliest opportunity. These should be put in writing to a member of Management.

The Company will ensure that any employee or associated person who makes a disclosure will not be penalised or suffer any adverse treatment for doing so. However, where it is found that the claim is intentionally untrue, was not made on reasonable grounds or for the purpose of personal gain, they may be subject to disciplinary action.

The Company is not prohibited from offering reasonable and proportionate hospitality and promotional or other business expenditure in order to improve image, present products or services or establish cordial relations as this is recognised as an established and important part of doing business.

Any breach of this policy is likely to constitute a serious disciplinary matter up to and including dismissal.