ANTI-BRIBERY POLICY AND PROCEDURES

ANTI-BRIBERY POLICY AND PROCEDURES (including third party due diligence, gifts & hospitality, conflicts of interest and facilitation payments)

January 2020

Anti-Bribery Policy Statement

• We do not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings, either with public officials and people in the private sector.
• We are committed to the following principles:
• We will carry out business fairly, honestly and openly.
• We will not give, promise or offer any money, gift, hospitality or other advantage to any person carrying out a business or public role, or to a third party associated with that person, to get them to do something improper.
• We will not give, promise or offer any money, gift, hospitality or other advantage to any public official or third party connected to a public official with the intention of influencing the public official to do something improper.
• Our sales representatives, distributors, installers and contractors or anyone else performing services on our behalf must not bribe in connection with our business.
• We do not allow employees or anyone else acting on our behalf to request, accept or agree to receive money, gifts, hospitality and other advantage from business associates, actual or potential suppliers, service providers or any other third party which are intended to influence a business decision or transaction in some improper way.
• Any employee found to be in breach of these principles will face disciplinary action.
• No employee will suffer demotion, penalty, or other adverse consequence for refusing to pay bribes, even if it may result in us losing business.
• We will avoid doing business with others who do not commit to doing business without bribery.
• We are committed to a programme to counter the risk of us being involved in bribery.

Any concerns relating to a breach of this policy should be reported to Gerry Devanney, CFO or Erin Neilson, Head of HR. Anonymous reports will not be investigated.