Introduction

The Company values its reputation for ethical behaviour and financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

• setting out a clear anti-bribery policy
• establishing and implementing anti-bribery procedures
• communicating this policy and relevant procedures to employees and to others who will perform services for the Company
• undertaking appropriate due diligence measures before engaging others to represent the Company in business dealings,
• monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures in place

Policy

The Company prohibits the offering, giving, solicitation or acceptance of any bribe (whether cash or other inducement)

• to or from any person or company (wherever they are situated and whether a public official or body or private person or company),
• by any individual employee, agent or other person or body acting on behalf of the Company,
• to gain any commercial, contractual or regulatory advantage for the Company in a way that is unethical,
• to gain any personal advantage (pecuniary or otherwise) for the individual or anyone connected with the
• This policy prohibits any inducement that results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action that may not be solely in the interests of the Company or of the person or body employing them or whom they
• This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift on a festival or other special time, providing they are customary in a particular market, are proportionate and are properly
• Inevitably, decisions as to what is acceptable may not always be easy. If in any doubt as to whether a potential act constitutes bribery, refer to a Manager before

Employees’ responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees and the Directors are committed to:

• encouraging employees to be vigilant and to report any suspicion of bribery,
• providing employees with suitable channels of communication and ensuring that sensitive information is treated appropriately,
• investigating instances of alleged bribery and assisting the police and other authorities in any resultant prosecution,
• taking disciplinary action against individual(s) involved in
• Any suspicion of bribery should be reported in confidence to the Managing Director, who has overall responsibility for bribery prevention.