Anti Corruption & Bribery

ANTI-CORRUPTION AND ANTI-BRIBERY STATEMENT

At Europartnership, we recognise that bribery and corruption are damaging to legitimate business interests. We conduct all our business – wherever in the World - in an honest and ethical manner, and we strive to ensure that all our associates and business partners do the same.

The UK Bribery Act 2010 sets clear standards of behaviour which govern our work in the UK and overseas. We are transparent and ethical in all our business dealings. We have a zero tolerance approach to financial crime. We will not allow our high ethical standards and reputation to be compromised by our association with any third party.

We have an anti-corruption and anti-bribery policy which sets the standards that we enforce as part of our ongoing commitment to implement adequate procedures to guard against illegal practices. Bribery and corrupt practices can flourish where secrecy and shady environments permit; our culture encourages openness and honesty to combat the threat of corruption.

We ask all who have dealings with Europartnership – whether as employees, agents, trading partners and customers - to help the fight against corruption.

 

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

1         At Europartnership, we conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and 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.

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

3         The purpose of this policy is to:

set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

4         Bribery and corruption are punishable for individuals by up to ten years' imprisonment and 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.

5         This policy applies directly to all individuals working at all levels within Europartnership as employees or agents and all our subsidiaries and their employees and agents, wherever located (collectively referred to as Direct Associates in this policy). The policy is provided to other associates of Europartnership, including our joint venture partners and suppliers, who will be required to comply with those provisions of the policy which apply to them (excluding for example any disciplinary sanctions) by the inclusion of relevant provisions in all contractual arrangements with Europartnership. In this policy, "third party" means any individual or organisation we come into contact with during the course of our work.

6         A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

7         There are four main offences under the Bribery Act 2010:

giving or offering a bribe;

receiving or requesting a bribe;

bribing a foreign public official; and

the corporate offence of failing to prevent bribery by an associated person for Europartnership' benefit.

8         This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from third parties.

9         Subject to the prior approval of the Chief Executive, and the other conditions set out in paragraph below, the giving or receipt of gifts or hospitality is not prohibited by a Direct Associate if all of 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 complies with local law;

it is given in our name, not in your name;

it does not include cash or a cash equivalent (such as gift certificates or vouchers);

it is appropriate in the circumstances. For example, it is given as a ceremonial gift on a festival or at another special time;

taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time;

it is given openly, not secretly; and

gifts or hospitality should not be offered to, or accepted from, government officials or representatives, or politicians or political parties,

10     The value of gift or hospitality items to be recorded and supported by appropriate documentation where practically possible.

11     It is not acceptable to:

give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given; or

promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure; or

accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them; or

accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return; or

threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

engage in any activity that might lead to a breach of this policy.

12     Any employee who breaches this policy may face disciplinary action that could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other Direct Associates if they breach this policy.

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

14     Our zero-tolerance approach to bribery and corruption is a public declaration to all suppliers, contractors and business partners.

15     The Chief Executive Officer will monitor the effectiveness and review the implementation of this policy, from time to time as required, considering its suitability, adequacy and effectiveness.