Anti-Bribery Policy

The Company is committed to the prevention of bribery by those employed and associated with it. We carry out business fairly, honestly and openly, with zero-tolerance towards bribery.

All employees have a responsibility to prevent, detect and report all instances of bribery.

The Company will:

• Carry out a risk assessment to ascertain the risk of bribery
• Instigate procedures proportionate to that risk
• Have good internal controls and record-keeping
• Secure the commitment of all employees to the prevention and detection of bribery
• Develop a culture in which bribery is unacceptable
• Undertake due diligence procedures proportionate to the assessed risk of bribery
• Effectively communicate the anti-bribery policy to all employees
• Train all employees to recognise bribery so they can avoid it and be alert to possible instances
• Have clear procedures on what to do should bribery be suspected
• Train all employees so they are aware of what to do should they discover a possible instance of bribery
• Monitor and review the effectiveness of bribery procedures and update them as necessary

Anyone who has concerns regarding acts or potential acts of bribery should speak to their Line Manager in the first instance. If for any reason you are not able to speak to your Line Manager, you should contact the CEO.

The Company expressly prohibits employees from offering, promising, giving, or requesting, agreeing to receive or receiving any financial or other advantage to another person or business with the intention of gaining an improper financial or other advantage.

The Company expressly prohibits the bribing of a UK or foreign public official in order to obtain or retain business or an advantage in the conduct of business.

Reasonable and proportionate hospitality, advertising, sponsorship and similar business expenditure is an established part of doing business. However, such expenditure can be used as bribes and must be handled carefully.

The Company expressly prohibits the giving and receiving of hospitality or business gifts where the intention is to receive or confer an advantage in return. The following rules apply:

• All offers of business gifts should be referred to and agreed by the CEO
• Business gifts should not be made without the permission of the CEO
• A record of all business gifts made and received, and the reason for the gift, should be retained
• All hospitality must be proportionate, reasonable and in line with the Company's hospitality policy, guidance should be sought from the CEO
• Records should be maintained of all hospitality provided and accepted, including cost and reason
• Quid pro quo arrangements are expressly prohibited
• Cash gifts are expressly prohibited
• The provision or acceptance of entertainment of a sexual nature is expressly prohibited
• Acceptable hospitality may include modest meals or occasional attendance at sporting or cultural events, provided the intention is to build business relationships
• Small promotional gifts such as diaries or pens will generally be regarded as acceptable
• Employees reviewing expense claims should be alert to hospitality or gifts that may be construed as a bribe
• All concerns should be reported

Where you develop or seek to develop new avenues for business or new contracts, or where the nature of the business changes, you should inform your Line Manager so that due diligence and a risk assessment can be undertaken.

Where a business relationship with an external party is sought or newly established, appropriate due diligence must be exercised. That external party must also be made aware of this anti-bribery policy.

The Company expressly prohibits facilitation payments of any sort. Any employee placed under pressure to make a facilitation payment should refer the matter to the CEO immediately.

The Company expressly prohibits the giving of donations to political parties. Any charitable donation must be consistent with the Company's policy on charitable giving and made with the knowledge and consent of the CEO.

The penalties for breaching the provisions of the Bribery Act 2010 are severe: