It is prohibited, directly or indirectly, to offer, give, request, or accept any bribe i.e., gift, loan, payment, reward, or advantage, either in cash or any other form of inducement, to or from any person or Company in order to gain commercial, contractual or regulatory advantage for us, or in order to gain any personal advantage for an individual or anyone connected with the individual in an unethical way.

It is also prohibited to act in the above manner to influence an individual in this capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe or solicited from an employee, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact your line manager so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you are working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to your line manager. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of the Company’s business partners breaching the anti-bribery rules.

We will ensure that all our transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in the employee’s dismissal if the individual is an employee, or the cessation of its arrangement with the person if the individual is self-employed, an agency worker, contractor etc.

We take any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise. All our employees are reminded of the Company’s Whistleblowing Policy, which is available in this Employee Handbook.

Anti-Bribery Policy and Corruption Policy