Anti-Bribery Policy

1. About this policy

1.1.

We conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption, and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

1.2.

We uphold all laws relevant to corruption and bribery in all jurisdictions in which we conduct business, including, in the UK, the Bribery Act 2010, which applies to conduct both in the UK and abroad.

1.3.

This policy applies to all persons working for us or on our behalf, in any capacity, including (but not limited to) employees at all levels, directors, consultants, casual and agency staff.

1.4.

Criminal law relating to bribery and corruption carries heavy penalties and you may commit a criminal offense if you fail to comply with this policy.

1.5.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

2. Bribery

2.1.

A bribe is a financial or other inducement or reward for an action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

2.2.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

2.3.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with Christopher Batts.

2.4.

Specifically, you must not:

- give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;

- accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;

- threaten or retaliate against another person working for us who has refused to commit a bribery offense or who has raised concerns under this policy; and

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

3. Corruption

3.1.

Corruption is the misuse of office or power for private gain.

3.2.

Bribery is a form of corruption.

4. Gifts and hospitality

4.1.

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from third parties unless otherwise specifically stated. We have provided guidance below as to what we regard as a normal and appropriate gift and hospitality:

- must be given in the name of the organization rather than an individual;

- must not include cash or a cash equivalent (such as vouchers);

- must be of an appropriate type and value and given at an appropriate time;

- must not be unduly lavish or extravagant; and

- must be given openly.

4.2.

Different parts of the world have different social and cultural customs. In some cultures, refusing or failing to offer a gift is considered impolite and could negatively impact a client relationship. In such cases, please report this to a director.

5. Responsibilities

5.1.

You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties and record the reason for expenditure.

5.2.

We keep a gifts and hospitality register noting down any gifts received. Please contact Christopher Batts if you have received any gifts from other businesses. We do not record promotional gifts (for example, branded pens and notepads).

5.3.

You are expected to follow this policy at all times and avoid any activity that might lead to, or suggest, a breach of this policy.

5.4.

You are expected to report any cases where you know, or have reason to believe, that bribery or corruption has occurred or if you are offered a bribe or asked to make one. Grievances are concerns or complaints that an employee has about an issue at work.

6. Questions about this policy

6.1.

If you have any questions about this policy, please contact Christopher Batts whose email address is hello@setyl.com