Anti-Bribery and Corruption Policy

Bribery corrupts decisions. This policy sets out how the Company keeps it out of its business.

1. Commitment

The Group does not tolerate bribery or corruption in any form. This policy is designed as an adequate procedure under section 7 of the Bribery Act 2010 and applies equally in every country where the Group works.

2. Scope

Directors, employees, contractors and anyone acting on behalf of the Group (“associated persons”).

3. Prohibited conduct

• Offering, promising or giving a bribe (s.1).
• Requesting, agreeing to receive or accepting a bribe (s.2).
• Bribing a foreign public official (s.6).
• Facilitation payments, of any size.
• Using intermediaries or donations to do indirectly what may not be done directly.

4. Gifts and hospitality

Permitted only if reasonable, proportionate, given openly, not intended to influence a decision, and recorded in the gifts and hospitality register. Gifts to or from public officials require prior approval. Cash or cash equivalents are never permitted.

5. Third parties

Partners, agents and suppliers are subject to risk-based due diligence, contractual anti-bribery clauses and the Supplier Code of Conduct.

6. Political and charitable contributions

The Group makes no political contributions. Charitable donations require Board approval and are recorded.

7. Raising concerns

Concerns can be raised through the confidential disclosure channel, anonymously if preferred. No one will suffer detriment for refusing to pay a bribe or for raising a concern in good faith.

8. Consequences and review

Breach may lead to disciplinary action, termination of contracts and referral to the authorities. The Board reviews this policy at least annually.