Bribery Policy

1. Policy statement

1.1 Waveney Precision Ltd is committed to conducting business in an ethical and

honest manner, and is committed to implementing and enforcing systems that

ensure bribery is prevented.

Waveney Precision Ltd has a 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.

1.2 Waveney Precision Ltd 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 regards to our conduct both at home and

abroad.

1.3 Waveney Precision Ltd 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.

2. Who is covered by the policy?

2.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term,

or permanent), consultants, contractors, trainees, seconded staff, home workers,

casual workers, agency staff, volunteers and agents.

3. Definition of bribery

3.1 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.

3.2 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.

3.3 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.

3.4 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 bribe a foreign public official anywhere in the

world. They must not accept bribes in any degree and if they are uncertain about

whether something is a bribe or a gift of hospitality, they must seek further advice

from the company’s compliance manager.

4. What is and what is NOT acceptable

4.1 This section of the policy refers to 4 areas:

• Gifts and hospitality.

• Facilitation payments.

• Political contributions.

• Charitable contributions.

4.2 Gifts and hospitality

Waveney Precision Ltd accepts normal and appropriate gestures of hospitality and

goodwill (whether given to/received from third parties) so long as the giving or

receiving of gifts meets the following requirements:WaCOMPANY NA

a. It is not made with the intention of influencing the party to whom it is being

given, to obtain or reward the retention of a business or a business advantage,

or as an explicit or implicit exchange for favours or benefits.

b. It is not made with the suggestion that a return favour is expected.

c. It is in compliance with local law.

d. It is given in the name of the company, not in an individual’s name.

e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas

or as a small thank you to a company for helping with a large project upon

completion).

g. It is of an appropriate type and value and given at an appropriate time, taking

into account the reason for the gift.

h. It is given/received openly, not secretly.

i. It is not selectively given to a key, influential person, clearly with the intention

of directly influencing them.

j. It is not above a certain excessive value (usually in excess of £100).

k. It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s Managing

Director.

4.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an

individual of a certain religion/culture who may take offence), the gift may be

accepted so long as it is declared to the Office manager/ Managing Director who will

assess the circumstances.

4.4 Waveney Precision Ltd recognises that the practice of giving and receiving

business gifts varies between countries, regions, cultures, and religions, so

definitions of what is acceptable and not acceptable will inevitably differ for each.

4.5 As good practice, gifts given and received should always be disclosed.

4.6 The intention behind a gift being given/received should always be considered. If

there is any uncertainty, advice should be sought.

4.7 Facilitation Payments and Kickbacks

Waveney Precision Ltd does not accept and will not make any form of facilitation

payments of any nature. We recognise that facilitation payments are a form of

bribery that involves expediting or facilitating the performance of a public official for

a routine governmental action. We recognise that they tend to be made by low level

officials with the intention of securing or speeding up the performance of a certain

duty or action.

4.8 Waveney Precision Ltd does not allow kickbacks to be made or accepted. We

recognise that kickbacks are typically made in exchange for a business favour or

advantage.

4.9 Waveney Precision Ltd recognises that, despite our strict policy on facilitation

payments and kickbacks, employees may face a situation where avoiding a

facilitation payment or kickback may put their/their family’s personal security at risk.

Under these circumstances, the following steps must be taken:

a. Keep any amount to the minimum.

b. Ask for a receipt, detailing the amount and reason for the payment.

c. Create a record concerning the payment.

d. Report this incident to your line manager.

4.10 Political Contributions

Waveney Precision Ltd will not make donations, whether in cash, kind, or by any

other means, to support any political parties or candidates. We recognise this may

be perceived as an attempt to gain an improper business advantage.

4.11 Charitable Contributions

Waveney Precision Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial

contributions (cash or otherwise) – and agrees to disclose all charitable contributions

it makes.

4.12 Employees must be careful to ensure that charitable contributions are not used

to facilitate and conceal acts of bribery.

4.13 We will ensure that all charitable donations made are legal and ethical under

local laws and practices, and that donations are not offered/made without approval.

5. Employee Responsibilities

5.1 As an employee of Waveney Precision Ltd, 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.

5.2 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.

5.3 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

management.

5.4 If any employee breaches this policy, they will face disciplinary action and could

face dismissal for gross misconduct.

Waveney Precision Ltd has the right to terminate a contractual relationship with an

employee if they breach this anti-bribery policy.

6. What happens if I need to raise a concern?

6.1 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.

6.2 How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in

relation to Waveney Precision Ltd, 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, the Office Manager or the Managing Director.

6.3 Whistleblowing

Waveney Precision Ltd will familiarise all employees with its whistleblowing

procedures so employees can vocalise their concerns swiftly and confidentially.

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

You must tell your manager 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.

6.5 Protection

If you refuse to accept or offer a bribe or you report a concern relating to potential

act(s) of bribery or corruption, Waveney Precision Ltd understands that you may feel

worried about potential repercussions. Waveney Precision Ltd will support anyone

who raises concerns in good faith under this policy, even if investigation finds that

they were mistaken.

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6.6 Waveney Precision Ltd 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.

6.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or

unfavourable treatment in relation to the concern the individual raised.

6.8 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 manager

immediately.

7. Training and communication

7.1 Waveney Precision Ltd provides this policy along with other policies which are

available to read from the office.

8. Record keeping

8.1 Waveney Precision Ltd will keep detailed and accurate financial records, and will

have appropriate internal controls in place to act as evidence for all payments made.

We will declare and keep a written record of the amount and reason for hospitality or

gifts accepted and given, and understand that gifts and acts of hospitality are subject

to managerial review.

9. Monitoring and reviewing

9.1 Waveney Precision Ltd is responsible for monitoring the effectiveness 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

compliance manager.

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

Waveney Precision Ltd may amend it at any time so to improve its effectiveness at

combatting bribery and corruption.

Signed

Alan Smith

Managing Director

Waveney Precision Ltd

Rev 1 06/09/2019