Anti-corruption and Bribery Policy

(Reviewed on 20 Sept 2023 by the Operations Manager)

Anti-corruption and Bribery Policy

1. ABOUT THIS POLICY

1.1 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 does not form part of any employee's contract of employment and we may amend it at any time.

2. THE RULES

2.1 It is not acceptable for you (or someone on your behalf) to: (a) give, promise to give, or offer any payment, gift, hospitality or other benefit in the expectation or hope that a business advantage will be received in return, or to reward any business advantage already given; (b) induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage; (c) accept any payment, gift or hospitality 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 in return; or (d) give, promise to 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.

2.2 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.

3. GIFTS AND HOSPITALITY 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.

4. RECORD-KEEPING 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.

5. HOW TO RAISE A CONCERN

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your line manager or report it in accordance with our Whistleblowing Policy as soon as possible.

6. BREACHES OF THIS POLICY

6.1 Any employee who breaches this policy will face disciplinary action, which could result in summary dismissal.

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