Staff Handbook - Policies and Procedures

(iii) Entertainment or hospitality offered or provided to the Company or any employee or agent or contractor on behalf of the Company can be only be accepted on the basis that there is absolutely no expectation or implication by the Company or by any other party that anyone who is in receipt of such entertainment or hospitality will perform a function or activity other than in good faith, impartially, or in a position of trust and to the standard of what a reasonable person in the UK would expect in relation to the performance of the type of function or activity involved. e) Training. All employees and agents and contractors of the Company shall receive training in the Bribery Policy and the procedures adopted by the Company to prevent bribery. f) Due Diligence Enquiries. All employees, agents, contractors and those otherwise associated with the Company shall during the recruitment or contracting process be subject to enquiries to ensure that they have not participated in past acts of bribery. Monitoring and training. The Company shall monitor the Register of entertainment, hospitality, and gifts. The Company has appointed a Compliance Officer who is responsible for maintaining the Register and monitoring the activities of the Company to ensure that the Policy and Preventative measures contained in the policy are adhered to. All staff and agents and contractors shall undergo training. What to do if you suspect bribery or corruption. Any employee or anyone associated with the company who suspects that there is bribery or corruption must report it to the Compliance Officer. Our Whistleblowing Policy applies to all reports of suspected bribery or corruption. If you are offered a bribe or asked to make a bribe you must report this. We are committed to ensure that no one suffers any detriment as a result of refusing to accept or take part in bribery or corruption or reporting their concerns or suspicions of bribery or corruption in good faith. If you believe that you have suffered such a detriment you should raise it under the Grievance Procedure. Donations to charity, political donations and sponsorships. Payments made as donations to charity or political organisations or parties and sponsorships may be used as a subterfuge to hide bribery. We have written policies regulating all such activity in our business which must be adhered to. Summary and conclusions. The Company has a zero policy on bribery. It has assessed the risk of bribery in the conduct of its business and implemented preventative measures to prevent bribery. Signed

Mr C J Sedgeman, Managing Director Dated: 24-06-24

Anti Bribery and Corruption Policy 24-06-24 Registered Office: Unit 2A Longrock Industrial Estate, Penzance, Cornwall. TR20 8HX Company Reg. No. 04124350 VAT Reg. No. 684598666 UTR No. 24386 09541

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