Seek Guidance:

Be open. Report any concerns, and if you are in any doubt, seek guidance on what you should do. Never try to conceal or disguise your actions.

If you are unsure whether something is permitted or not seek guidance before committing yourself or the company.

Senior management needs to be aware of the bribery risks that we face. Accordingly if someone within or outside the company requests or offers anything which might be regarded as a bribe, report it.

What to do:

If you or anyone else may have paid a bribe or engaged in unethical conduct, you must report it in accordance with our Whistleblowing Policy as soon as possible.

You must also declare and keep a written record of all hospitality or gifts given or received.

You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

If you have made an error of judgement, but then report it, we will show appropriate understanding. If you make such an error but then seek to conceal or disguise your actions this will be regarded very seriously.

Record Keeping:

In particular, keep accurate records. Serious corruption offences in other businesses have often involved inaccurate record-keeping. Making false records is a criminal offence.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness.

Accounts must not be kept “off-book” to facilitate or conceal improper payments.

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