1. WHAT DOES YOUR POLICY COVER?

 

1.1 This anti-bribery policy exists to set out the responsibilities of RiskSTOP Group and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption.

 

1.2 It also exists to act as a source of information and guidance for those working for RiskSTOP Group. It helps them recognise and deal with bribery and corruption

issues, as well as understand their responsibilities.

 

2. POLICY STATEMENT

 

2.1 RiskSTOP Group is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. RiskSTOP Group has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

 

2.2 RiskSTOP Group will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regard to our conduct both at home and abroad.

 

2.3 RiskSTOP Group recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

 

3. WHO IS COVERED BY THE POLICY?

 

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, agency staff, agents, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Board members and all Shareholders.

 

3.2 In the context of this policy, third-party refers to any individual or organisation our

company meets and works with. It refers to actual and potential clients, customers,

suppliers, distributors, business contacts.

 

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

 

4. DEFINITION OF BRIBERY

 

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving,

accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

 

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

 

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

 

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s Managing Director.

 

5.  GIFTS AND HOSPITALITY

 

5.1 RiskSTOP Group does not accept nor provide any gestures of hospitality and goodwill such as gifts, facilitation payments or political contributions.

 

6. EMPLOYEE RESPONSIBILITIES

 

6.1 As an employee of RiskSTOP Group, you must ensure that you read,

understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

 

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

 

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the Managing Director.

 

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. RiskSTOP Group has the right to terminate a

contractual relationship with an employee if they breach this anti-bribery policy.

 

7. WHAT HAPPENS IF I NEED TO RAISE A CONCERN?

 

7.1 This section of the policy covers 3 areas:

a. How to raise a concern.

b. What to do if you are a victim of bribery or corruption.

c. Protection.

 

7.2 How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to RiskSTOP Group, you are encouraged to raise your concerns at as early

a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager or a director as appropriate.

 

7.3 RiskSTOP Group will familiarise all employees with its whistleblowing

procedures so employees can vocalise their concerns swiftly and confidentially.

 

7.4 What to do if you are a victim of bribery or corruption

You must tell your line manager or a director as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

 

7.5 Protection

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, RiskSTOP Group understands that you may feel worried about potential repercussions. RiskSTOP Group will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

 

7.6 RiskSTOP Group will ensure that no one suffers any detrimental treatment

as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

 

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

 

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the Managing Director immediately.

 

8. TRAINING AND COMMUNICATION

 

8.1 RiskSTOP Group will communicate this policy as part of the induction process for all new employees and will provide full access via its chosen website for the benefit of all stakeholders.

 

8.2 RiskSTOP Group’s anti-bribery and corruption policy and zero-tolerance

attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

 

9. MONITORING AND REVIEWING

 

9.1 RiskSTOP Group’s board is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

 

9.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

 

9.3 Any need for improvements will be applied as soon as possible. Employees are

encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Managing Director.

 

9.4 This policy does not form part of an employee’s contract of employment and

RiskSTOP Group may amend it at any time so to improve its effectiveness at

combatting bribery and corruption