The Group is fully committed to instilling a strong anti-corruption culture, rejecting bribery in all forms, and will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, irrespective of our country of operation, we remain bound by UK laws, including the Bribery Act 2010.

• The Group’s Anti-Bribery and Corruption Policy applies to all persons working for any Group Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever they may be located. It is the responsibility of all the above-mentioned parties to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with the Group’s Whistle Blowing Policy or utilising the Speak-Up Line.
• We may not offer, promise, give or authorize the presentation of anything of value, directly or indirectly, to anyone for the purpose of obtaining an improper business advantage.
• We may not request or agree to receive any financial or other advantages from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.
• Facilitation payments constitute bribes and may not be made at any time irrespective of prevailing business customs in certain territories. Facilitation or similar payments may be made in limited circumstances where life is in danger but under no other circumstances. Any payment so made must be reported to the Compliance Officer as soon as reasonably possible and practical.
• While gifts and hospitality remain a legitimate part of conducting business, it should only be provided in compliance with the strict requirements of the Anti-Bribery and Corruption Policy.
• Charitable donations are permitted only to organisations that are legal and ethical in terms of local legislation. No donation must be offered or made on behalf of any Group Company without the prior approval of the Group CEO.
• Charitable donations are permitted only to registered (non-profit) charities.
• The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.