Company Policy


Equal opportunities and discrimination policy

The Company recognises that discrimination is not only unacceptable, it is also unlawful.
The Company’s aim is to ensure that no job applicant or employee is discriminated against,
directly or indirectly, on any unlawful grounds.
By including this policy in the Employee Handbook, all employees are made aware that the
Company will act in accordance with all statutory requirements and take into account any
relevant codes of practice.
All job applicants will be considered solely on their ability to do the job. Interview questions
will not be of a discriminatory nature.
All promotions will be made on merit in line with the principles of the policy.
Employees who have a disability will receive the necessary help, within reason, to enable
them to carry out their normal duties effectively.
This policy will be assessed at regular intervals to ensure that equality of opportunity is
afforded to all employees.

Anti-bribery policy

Introduction

The Company values its reputation for ethical behaviour and for financial probity and
reliability. It recognises that over and above the commission of any crime, any involvement
in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit
its exposure to bribery by:
• setting out a clear anti-bribery policy,
• establishing and implementing anti-bribery procedures as appropriate,
• communicating this policy and any relevant procedures to employees and to
others who will perform services for the Company,
• undertaking appropriate due diligence measures before engaging others to
represent the Company in its business dealings,
• monitoring and reviewing the risks and the effectiveness of any anti-bribery
procedures that are in place.
Policy
The Company prohibits the offering, giving, solicitation or acceptance of any bribe (whether
cash or other inducement)
• to or from any person or company (wherever they are situated and whether
they are a public official or body or private person or company),
• by any individual employee, agent or other person or body acting on behalf of
the Company,
• in order to gain any commercial, contractual or regulatory advantage for the
Company in a way that is unethical,
• or in order to gain any personal advantage (pecuniary or otherwise) for the
individual or anyone connected with the individual.
This policy prohibits any inducement that results in a personal gain or advantage to the
recipient or any person or body associated with them, and which is intended to influence
them to take action that may not be solely in the interests of the Company or of the person or
body employing them or whom they represent.
This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift
on a festival or at another special time, providing they are customary in a particular market,
are proportionate and are properly recorded.
Inevitably, decisions as to what is acceptable may not always be easy. If you are in any doubt
as to whether a potential act constitutes bribery, the matter should be referred to a Director
before proceeding.
Employees’ responsibility
The prevention, detection and reporting of bribery is the responsibility of all employees and
the Company is committed to:
• encouraging employees to be vigilant and to report any suspicion of bribery,
• providing employees with suitable channels of communication and ensuring
that sensitive information is treated appropriately,
• investigating instances of alleged bribery and assisting the police and other
appropriate authorities in any resultant prosecution,
• taking disciplinary action against any individual(s) involved in bribery.
Any suspicion of bribery should be reported in confidence to the Managing Director, who has
overall responsibility for bribery prevention.