Anti-Bribery Statement

Policy Statement

The Company takes a zero tolerance approach to bribery of any kind, from employees as well as third parties.

The Company will not work with parties who refuse to commit to doing business with proper anti-bribery policies and procedures in place.

Compliance

No cash gifts may be given or accepted by employees under any circumstances.

No employee of the Company should offer or provide anything of value to a customer that is intended to be or might be perceived as being a bribe. This includes not just money and gifts but also material, equipment, services and information.

You must immediately report the following to the Managing Director in the first instance or another Director if the Managing Director is not available:

• If you are faced with a bribe or attempted blackmail;
• If you believe that a colleague, customer, supplier or third party with whom the Company does business has breached the terms of this policy; or
• If you have done anything in breach of the terms of this policy.

Staff should not take advantage of their position in dealing with suppliers to obtain personal discounts for themselves, their families and/or friends, nor should any offers from suppliers or potential suppliers to do private work for members of staff be accepted, unless demonstrably on terms that would be applicable to the general public or agreed by management.

Responsibility for the Policy

The Board of Directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations. The Managing Director has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.

Training and Communication

Regular training on this policy, and on the risk that the business faces from bribery, will be provided to management and staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

The Company’s zero tolerance approach to bribery and must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Breach of the Policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

Date: January 2024
Name: Grant Dixon
Position: Managing Director