Anti - Bribery Policy

As an employer and a provider or procurer of works, goods and services, we will not tolerate any contravention of the Act.

We will not employ individuals nor conduct business with any individual or third party which does not abide by the terms of the Act. Any suspected contravention of the Act will be investigated internally, and where we consider that a breach of the Act has occurred, this will be referred to the relevant regulatory authorities for further action as appropriate.

We will appoint an officer who shall have responsibility for ensuring that adequate procedures and appropriate documents are put in place to reflect the requirements placed upon us and associated persons under the Act such as its officers, suppliers and partners. This will include, but is not limited to: the Codes of Conduct; the Employee Handbook; our Procurement Manual; associated tender documentation; guidance on the acceptance of gifts and hospitality; and the Register of Interests.

Thereafter, the responsible officer will regularly monitor and review our procedures and documents and keep the members advised of any breaches of the Act. We expect that all the partner organisations (including its ALEOs) have an interest in and will behave in a similar manner. The external governance scrutiny committee (or successor committee) will have oversight of the arrangements made by our arms length organisations to implement the practices and procedures necessary to comply with legislation and to maintain their and our reputation.