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The Bribery Bill received Royal Assent on 8 April 2010 thereby becoming the Bribery Act 2010 (“The Act”) and came into force on 1 July 2011. The Act makes it an offence to give or receive a bribe or to promise, offer or agree to receive a bribe. The maximum penalty for individuals will be 10 years’ imprisonment and/or a fine.
The maximum penalty for a company will be an unlimited fine. This document sets out the rules of ICoNiChem in relation to the above Bribery Act and corruption matters in the United Kingdom and worldwide.

Anti-Bribery Policy

Introduction
One of the Company’s core values is to uphold responsible and fair business practices. It is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintain lawful business practices is paramount importance and this policy is designed to preserve these values. The Company therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems to counter bribery.

Purpose and scope of policy
This policy sets out the Company’s position on any form of bribery and corruption and provides guidelines aimed at:

  • Ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which the Company may carry out its business or in relation to which its business may be connected.
  • Enabling employees and persons associated with the Company to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether themselves or others.
  • Providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with.
  • Creating and maintaining rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

 
This policy applies to all permanent and temporary employees of the Company (including its intermediates, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with the Company, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors (“associated persons”). All employees and associated persons are expected to adhere to the principles set out in this policy.

Legal Obligations
The UK legislation on which this policy s based is the Bribery Act 2010 and it applies to the Company’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

  • Offer, promise or give a financial or other advantage to another person (ie bribe a person), whether in the UK or abroad, with the intention of inducing or rewarding improper conduct.
  • Request, agree to receive or accept a financial or other advantage (ie receive a bribe) for or in relation to improper conduct.
  • Bribe a foreign public official.

 
You can be held personally liable for any such offence.

It is also an offence in the UK for an employee or associate person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain and advantage in the conduct of business, for the Company. The Company can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage.

Policy statement
All employees and associated persons are required to:

  • Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business.
  • Act honestly, responsibly and with integrity
  • Safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.

 
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.

The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one p lace may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this policy is expected of all employees and associated persons at all times. If in doubt as to what might amount to bribery, or what might constitute a breach of this policy, refer the matter to your line manager or the Company’s anti-corruption officer.

For the Company’s rules and procedures in relation to the receipt of business gifts from third parties and corporate hospitality offered to or received from third parties, please refer to the employee handbook. They form part of the Company’s zero tolerance policy towards bribery and the company handbook should be read in conjunction with this policy.

The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:

  • The gift 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
  • It complies with local law
  • It is given in the Company’s name and not the giver’s personal name
  • It does not include cash or a cash equivalent, such as gift vouchers
  • It is of an appropriate and reasonable type and value and given at an appropriate time
  • It is given openly and not secretly
  • It is approved in advance by a director of the Company

In summary, 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 to be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.

Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance or a routine government procedure or process, otherwise known as a “facilitation payment” is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.

FG Jones
Financial Director
Version 3: Oct 2020
Next Review Date: Oct 2021

Anti-Slavery And Human Trafficking Policy

Policy Statement
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. The Company also expects the same high standards from all its suppliers, contractors and other business partners and, as part of its contracting process, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through the due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for the company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the policy
The board of directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.

The Operations Director has day to day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.

Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance
The preventions, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy.

If you believe or suspect a breach of or conflict with this policy has occurred, you must notify your line manager or report it in accordance with the Company disclosures in the public interest. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with y our line manager. You can also contact the Government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

Training
Regular training on this policy, on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering in to new or renewed contracts with them.

Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

The Company may terminate its contractual relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

FG Jones
Financial Director
Version 3: Oct 2020
Next Review Date: Oct 2021