Anti-Bribery Policy & Process

1 Policy statement

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

Bribery and corruption are punishable for individuals by up to 10 years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation.

We therefore take our legal responsibilities very seriously.

2 Scope

a. Who is covered by the policy?

In this policy, third party means any individual or organisation we come into contact with during the course of our business, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), apprentices, consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.

This policy covers:

• Bribes;

• Gifts and hospitality;

• Facilitation payments;

• Undue pressure;

• Political contributions;

• Charitable contributions.

b. Bribes

We will not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, we will not bribe a public official anywhere in the world.

c. Gifts and hospitality

The giving and receiving of gifts and hospitality is considered acceptable only for the purposes of:

• establishing or maintaining good business relationships;

• improving or maintaining the business’ image or reputation; and

• marketing or presenting our products and/or services effectively.

And where the following requirements are met:

• It is not made 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.

• It is given in the company’s name.

• It does not include cash or a cash equivalent (such as gift certificates or vouchers).

• It does not exceed £150 in value, unless expressly approved by our Directors, in writing.

• It is appropriate to the circumstances, taking into account the reason for the gift, its timing and value. For example, in the UK, it is customary for small gifts to be given at Christmas.

• It is given openly, not secretly.

• It complies with any applicable local law.

We will not offer, give or accept any gift or hospitality:

• which could be regarded as illegal or improper, or which violates the recipient’s policies;

• to or from any public employee or government officials or representatives, or politicians or political parties; and

• where there is any suggestion that a return favour will be expected or implied.

d. Undue Pressure

Undue pressure is a form of bribery whereby an individual is pressured into performing an act (e.g. ensuring a vehicle receives an MOT pass) by a third party. This may occur under the threat of losing business from that third party.

If an employee or other representative of Brickhunter Ltd feels unduly pressured by a third party, then they must report this to the Directors immediately and will not agree to perform the act where this will breach our professional obligations.

e. Political Contributions

We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

f. Charitable contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in-kind services, knowledge, time, or direct financial contributions.

However, we will exercise diligence in ensuring that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation will be offered or made without the prior approval of the Directors.

All charitable contributions will be publicly disclosed.

3 Your responsibilities

Our zero-tolerance approach to bribery and corruption applies to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

You must ensure that you read, understand and comply with this policy.

You must notify the Directors as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.

We reserve our right to terminate contractual relationships which we believe may involve or lead to any activity which may lead to or suggest a breach of this policy.

4 Record-keeping

We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

We will keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

We will ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

5 How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage using the Company Whistleblowing procedure. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with the Directors.

The Managing Director has overall responsibility for this policy and its application.

6 What to do if you are a victim of bribery or corruption

It is important to inform our Directors as soon as possible if you are offered a bribe or, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform the Directors immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.

7 Protection

Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

8 Monitoring and review

The Managing Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

Last reviewed: May 2022