The Bribery Act 2016 Compliance Policy, Practices and Procedures 1.

This document (“the Policy”) has been approved by the Board of Directors and describes the policy of Company together with the practices and procedures to be followed in order to comply with section 7 of the Bribery Act 2010.

2. It is an offence under section 7 for a “relevant commercial organisation” such as this Company to fail to prevent bribery. In this context it is liable if a person associated with it (a Director, an employee, an agent) commits an act of bribery whether that person is prosecuted or not.

3. It is, however, a defence to any such criminal allegation to show, on a balance of probabilities, that the organisation nevertheless had adequate procedures in place to prevent persons associated with it from bribing. This policy describes the measures this Company has adopted and has put into place. It comes into force on 10th November 2010 and applies to all acts done by or on behalf of the Company thereafter.

Mission Statement 4. The Company is committed to running a professional business free from discreditable behaviour of any kind. It is particularly committed to Principle 2 of the Guidance given under the Bribery Act by the Ministry of Justice, that is, to prevent bribery by persons associated with it.

5. In order to prevent the unwitting engagement in behaviour which might raise the suspicion of bribery and to prevent any associated person purporting to act on its behalf in a manner that brings suspicion on the Directors and employees, the following measures have been adopted as appropriate and proportionate to the risks it faces.

They will be enforced by their dissemination, regular training and disciplinary measures. Any resources that are required to implement any compliance measures are to be made available.

Management 6.

The responsibility for compliance of this policy rests with the top level of management of the Company, which will exercise oversight, make assessments of risk, deal with decisions where potential for bribery exists, receive and investigate reports of bribery and supervise the measures put in place to prevent bribery.

Bribery Act

11 Belper Walk


M18 8AZ .

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