Anti-Bribery Policy

1. The Company has a strict anti-bribery and anti-corruption policy in accordance with the Bribery Act 2010.

2. A bribe is defined as giving a financial advantage (which includes any material benefit) to encourage that person to perform their functions or activities improperly or to reward that person for already having done so in order to give some kind of advantage either directly or indirectly to the giver.

3. Either giving or receiving a bribe is strictly against the Company’s policy and may be regarded as a serious breach of the Disciplinary Procedure amounting to gross misconduct.

4. Such an act of bribery would include accepting money, any items of value over £1.00, entertainment, meals, tickets to see any sports or entertainment or any other item or entertainment or benefit of any kind, including such items or services offered or purchased at a discount, and accepted directly by or on behalf of the recipient or any other party associated with the recipient and is intended to achieve some kind of benefit or preferment, whether successful or not, for the giver or any person or business associated with the giver.

5. Any employee found giving or receiving a bribe, in the reasonable belief of the Company’s Managing Director, may be dismissed for gross misconduct.

6. Any person who is offered or receives such a bribe or is reasonably aware that such a bribe has been given or received by an employee must immediately disclose the matter to the Managing Director of the Company. Failing to report such matter may result in the employee being dismissed for gross misconduct.

7. If any employee receives any benefit or any kind, he shall immediately disclose and hand over such benefit to the Company’s Managing Director to be disposed of as the Managing Director, in his absolute discretion, decides.

8. The Company reserves its rights generally and the Employee accepts that he may be held liable for the losses suffered by the Company as a result of his actions in breach of this policy.