Staff Handbook

Prohibited Conduct Employees are not permitted to engage in bribery. Any employee suspected of engaging in bribery will be subject to disciplinary proceedings and may be summarily dismissed, as bribery is considered an act of gross misconduct. In appropriate cases, the Company may also report the matter to the relevant authorities (e.g. the police) where it appears that a crime may have been committed. Reporting Suspected Bribery If you suspect that bribery may have taken place or is likely to take place, you should report your suspicions to a member of management who is not associated with the matter. An appropriate investigation will be carried out without delay and you will be required to co-operate with the investigation. Where you have reported an instance of bribery in good faith you will be fully supported by the Company and all reasonable measures will be taken to ensure that you do not suffer a detriment as a consequence of your report. Any instances of detrimental treatment by a fellow employee in connection with your report will be treated as a disciplinary offence. Corporate Hospitality and Gifts From time to time you may be offered or wish to offer a gift by/for a customer or supplier, or an invitation to an event or some other form of corporate hospitality. The Company has no objection to employees being rewarded for good work through an appropriate gift. The giving and receiving of hospitality on behalf of the Company can also be an entirely appropriate method of building relationships with customers and suppliers. But it is important that the giving and receiving of gifts and hospitality is done openly and that there can be no suggestion of impropriety. You must ensure, therefore, that you notify your line manager immediately if you are given or offered a gift or any hospitality in the course of your work. Your line manager will decide whether or not the gift/hospitality may be accepted or returned. In addition, your line manager will decide whether or not you should be allowed to keep any gift personally or whether it should be shared with other staff members. This will depend on the particular circumstances of the case. The Company will only authorise the giving, offering or receiving of gifts or hospitality if the following requirements are met: • they are not offered or given with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits; • they comply with local law;

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