Anti-Bribery and Corruption Policy

  1. Purpose and Scope

This Anti-Bribery and Corruption Policy (the “Policy”) outlines the standards and behaviours expected of all employees, contractors, and third-party partners to ensure compliance with all applicable anti-bribery and corruption laws. The Policy aims to prevent bribery and corruption in all business dealings, uphold ethical practices, and protect the integrity of the company.

  1. Policy Statement

Bribery and corruption are strictly prohibited. The company is committed to conducting business fairly, honestly, and transparently. All employees and associated persons must comply with this Policy and all relevant anti-bribery and corruption legislation.

  1. Definitions
  • Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of an official or other person in discharge of a public or legal duty.
  • Corruption: Abuse of entrusted power for private gain.
  • Facilitation Payments: Small, unofficial payments made to secure or expedite a routine governmental action.
  1. Prohibited Conduct
  • Offering, promising, or giving a bribe.
  • Requesting, agreeing to receive, or accepting a bribe.
  • Making facilitation payments.
  • Offering or accepting gifts or hospitality with the intention of influencing business decisions.
  1. Gifts and Hospitality

Gifts and hospitality are permitted only if they are:

  • Reasonable and proportionate.
  • Not intended to influence a business decision.
  • Compliant with local laws and regulations.
  • Reported and approved according to the company’s procedures.
  1. Third-Party Relationships
  • Due diligence must be conducted on third parties to ensure compliance with anti-bribery and corruption laws.
  • Third parties must be informed of and agree to comply with this Policy.
  • Monitoring and auditing of third-party compliance may be conducted.
  1. Responsibilities
  • Employees: Must comply with the Policy, attend training sessions, and report any concerns or violations.
  • Managers: Must ensure team members understand and comply with the Policy and provide support and resources for compliance.
  • Compliance Officer: Responsible for the implementation, monitoring, and enforcement of the Policy. Must ensure the Policy is up-to-date with current laws and best practices.
  1. Training and Communication
  • Regular training will be provided to employees on anti-bribery and corruption laws and the Policy.
  • The Policy will be communicated to all employees and relevant third parties.
  1. Reporting and Whistleblowing
  • Employees must report any suspected or actual bribery or corruption to the Compliance Officer.
  • The company will provide a confidential whistleblowing mechanism for anonymous reporting.
  • No retaliation will be tolerated against employees who report in good faith.
  1. Consequences of Non-Compliance
  • Violation of this Policy may result in disciplinary action, including termination of employment.
  • Legal action may be taken against individuals involved in bribery and corruption.
  • The company may terminate relationships with third parties who fail to comply with the Policy.
  1. Monitoring and Review
  • The Compliance Officer will regularly review and update the Policy to ensure effectiveness and adherence to legal requirements.
  • Internal audits will be conducted to assess compliance with the Policy.
  1. Contact Information

For questions or concerns about this Policy, contact the Compliance Officer at [email protected]/01229483850.

Appendix: Example Scenarios

Scenario 1: Gift Acceptance

Situation: An employee receives an expensive watch from a supplier during contract negotiations. Action: The employee should decline the gift and report the offer to the Compliance Officer.

Scenario 2: Facilitation Payment

Situation: A customs official requests a small payment to expedite the release of goods. Action: The employee must refuse the payment and report the incident to the Compliance Officer.

Scenario 3: Third-Party Due Diligence

Situation: The company is considering hiring a local agent to help with market entry. Action: Conduct due diligence on the agent, ensure they understand and agree to comply with the Policy, and monitor their actions regularly.

By adhering to this Policy, we ensure that our business practices uphold the highest standards of integrity and transparency, fostering trust with our stakeholders and protecting our company’s reputation.