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Bribery & ethics

Message from the Chief Executive Officer

Ipeco seeks to establish long term partnerships with our customers, suppliers and staff. The company has a progressive management attitude towards new product development, innovation and change implementation. Decision making has a long term emphasis with the welfare of all stakeholders at the forefront.

Ipeco are recognised as an innovative leader in our fields of expert ise, our sound reputation precedes us. Each employee, as a representative of Ipeco, is expected to behave in a responsible, ethical and professional manner and is accountable for maintaining the reputation of the company . In order to provide some guidance as to what is deemed acceptable professional behaviour, this policy provides an insight for all employees to the ethical business standards set by the company regarding bribery, and expected from each and every employee and representative in relation to the UK Bribery Act 2010.

Steve Johnson
Chief Executive Officer

Message from the Finance Director

Ipeco is committed to the highest possible standards of openness and accountability and to conduct its business in an honest and open way, without the use of corrupt practices or acts of bribery to obtain unfair advantage. Ipeco attaches the utmost importance to this policy and will apply a “zero tolerance” approach to acts of bribery and corruption by any of its employees or representatives. Any breach of this policy will be regarded as a serious matter and is likely to result in disciplinary action and possibly criminal prosecution.

As Finance Director for Ipeco, I have overall responsibility for our compliance in respect of bribery and corruption matters.

Sarah Nash
Company Secretary

1. Introduction

This policy on the code of conduct regarding bribery (herein referred to as the Policy) serves as a set of guidelines to the ethical and business standards all employees, both permanent and temporary including contracted or agency staff (herein referred to as Employees) are expected to adhere to in relation to compliance with the UK Bribery Act 2010 (herein referred to as the Act). It includes who has what responsibilities, defines what may constitute a bribe, details what to do if you have a concerns about ethical behaviours/conduct, as well as giving an outline to the Act.

All references in this Policy to Ipeco refer to Ipeco Holdings Limited as well as to all other companies and branches of companies in the Castledon Ltd group of companies

2. Company Commitment

Ipeco commits all management to abide by the same ethical standards expected of all Employees.

Ipeco will promote good ethical conduct within the business, with its Employees, in addition to being available to discuss any concerns regarding the ethical conduct of others which Employees wish to raise with Ipeco.

3. Overall responsibilities under this Policy

This Policy applies to and is MANDATORY for ALL Ipeco Employees. Any Business Partners who represent Ipeco must ensure they have an anti-bribery policy in place which is no less strict than this Policy and must not cause Ipeco or any Employee to breach this Policy.

4. Responsibilities of Managers, Supervisors and Team Leaders

It is the responsibility of all Managers, Supervisors and Team Leaders to:

a. familiarise their staff with this Policy;
b. provide guidance as needed regarding how to comply with this Policy; and;
c. monitor compliance by their staff with this Policy and ensure that their staff are able to speak up about ethical issues without fear of retribution.

All Managers, Supervisors and Team Leaders are expected to take ethical issues seriously and act accordingly to ensure that the standards set out in this Policy are maintained within Ipeco. This Policy has been set by the board of Directors (“the Board “) of lpeco which is responsible for the implementation and monitoring of this Policy.

5. Employee Responsibilities

All Employees must ensure that they read, understand and comply with this Policy at all times. Any clarification needed should be sought from your Team Leader, Supervisor, Manager or the person to whom you report to at Ipeco.

You will be required to confirm that you have read this Policy and agree to comply with its content.

All Employees are responsible for complying with Ipeco’s policies and procedures in the day-to-day conduct of business. The prevention, detection and reporting of bribery, corruption and/or ethical misconduct are both an individual and a collective responsibility and all Employees are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
If you believe or suspect that a breach of this Policy has occurred, or are uncertain whether a breach of this Policy may have occurred, you should notify your Team Leader, Supervisor, Manager or a Director immediately. If they are not available then you should notify one of the other Managers.

6. What is bribery?

A bribe is a financial or other advantage offered, promised or provided to or requested from another party with the intention on the part of the offeror or requestor (as the case may be) of improperly (that is, other than in the course of what would be regarded as standard business or market practice in the United Kingdom) inducing them to perform a function or activity improperly or to reward them for doing so to gain any commercial, contractual, regulatory or personal advantage, or (in the case of a bribe which is requested) in order to perform a function or activity improperly, other than in the ordinary course or otherwise than as is legally required or stipulated.

A bribe may include any payment, benefit, advantage or gift offered, accepted, received, requested or given with the purpose of influencing a decision or outcome. A bribe may not necessarily be of a large monetary value and could be simply a lunch or an invitation to a sporting event. It might also include intangible benefits such as the provision of information, advice or assistance in arranging a business transaction or a paid or unpaid internship for a friend or relative. If it is offered, requested or accepted with the purpose of influe ncing a decision or outcome in relation to Ipeco’s business dealings, such a gift could be regarded as a bribe. Offering, requesting and/or agreeing to accept a bribe is still a bribe, and it doesn ‘t matter if the bribe is ultimately paid or not.

7. Gifts and hospitality

This Policy does not prohibit normal, appropriate and proportionate gifts and hospitality, both given and received, to or from third parties. However, any gifts or hospitality given or received must be in accordance with the provisions of this Policy.

All Employees’ actions MUST be able to withstand scrutiny, and not cause any embarrassment to Ipeco or the Employee (as the case may be) or any third party, including Ipeco’s customers and suppliers .

To ensure openness and transparency, all gifts and hospitality must be recorded in Ipeco’s gift register ( “the Register”) within 30 days of its occurrence.

The Register must, in relation to hospitality, detail the attendees, (of both Ipeco and the other person concerned), the date, location and country of the hospitality or entertainment held and the cost or approximate value of the hospitality given or received.

The Register must, in relation to gifts, detail the gift, to whom the gift was given or from whom the gift was received (as the case may be), the approximate value of the gift and the date, location and country of where the gift was offered or received.

This Register is accessed via the ‘Forms’ section of t he HR Website and is reviewed on a month ly basis by the Finance Director.

8. Gifts

Employees may accept token gifts such as pens, stationery, branded clothing and other corporate items produced for the purpose of being given away, if the value is unlikely to exceed £50. These items do not need to be recorded in the Register.

More expensive gifts, for example, a case of wine, a weekend trip, free flights and the like should not be accepted by individual Employees and must be discussed with the Finance Director before being accepted. The Finance Director will decide whether such a gift could be construed as an inducement or bribe and will confirm if such a gift is acceptable.

Where there is no risk of the gift or benefit being construed as an inducement such gifts may be approved by the Finance Director for acceptance by the individual person, or on behalf of Ipeco, so that they may be raffled with the proceeds donated to charity. Where a risk of potential inducement is identified, such gifts will be declined for acceptance .
For clarity, all Employees must refuse personal gifts such as Christmas, wedding or birthday gifts, including vouchers or cash equivalents, received from actual or potentia l business partners, suppliers, agents, consultants, advisors and other persons with which Ipeco does business or may do business in the future (“Partners”).

In some parts of the world it is customary for individuals to exchange gifts in various business related contexts. If you are engaged in business in such locations a gift can be accepted and a reciprocal gift of a reasonable value may be given, if approved by the Finance Director . However, the accepted gift (if its value exceeds £50) must be registered in the Register and should be flagged “international”. It will then be entered into a raffle with the proceeds donated to charity .

Any gifts that Employees offer to a Partner (actual or potential) must also be acceptable within the policy of the relevant Partner’s Company/organisation. You should not put yourself in a position where you and/or they could be open to accusations of inducement. Therefore, if you are in any doubt about the acceptability of a gift of benefit you are giving, no gift or benefit should be provided until such time as the matter has been discussed with, and the required approval obtained from, the Finance Director.

You are permitted to give or receive gifts on behalf Ipeco provided that:

  • it is not made with the intention of influencing you (in the case of receiving a gift) or a third party (in the case of giving a gift) to perform your/their duties in an improper manner such as (but not limited to) obtaining or retaining a business advantage, rewarding the provision of a business advantage or the exchange of favours and/or benefits;
  • it complies with local law (please note that this is different to local custom), especially in circumstances where Ipeco conducts business outside the UK;
  • it is given or received in good faith and is occasional, and taking into account all the circumstances it is proportionate, appropriate and reasonable, complies with any applicable laws, and is given or received at an appropriate time;
  • it is given or received openly and is not secretive in nature; and
  • in relation to Public Officials (see Section 12 of this Policy), it is not given or received without the prior approval of a Company Director.

Although guidance has been given in this Policy as to what may be acceptable, you should have regard at all times to whether, in considering all the circumstances, the gift is reasonable, proportionate and justifiable. On each occasion you should consider the intention behind the gift and whether in receiving the gift you are being asked to perform your duties in an improper way.

If you do not accept a gift you must inform your Manager who will advise whether the offer of a gift still needs to be logged in the Register.

9. Hospitality

Employees may occasionally receive invitations from third parties, including Partners, to corporate hospitality or entertainment events.
Hospitality or entertainment may only be accepted if:

  • Employees or personnel from a Partner are in attendance;
  • the Partner/relevant third party does not pay any accommodation or (more than trivial) travel expenses for the Employees; and
  • the entertainment and/or acceptance of it could not be interpreted as a reward, inducement or encouragement for a favour, to influence the outcome of agreements or negotiations or to solicit preferential treatment.

Reciprocal hospitality may be offered but needs to be approved by your Manager; for example when an overseas supplier visits the UK.
Any hospitality offered, given or received shall:

  • be in good faith, occasional, appropriate, proportionate and reasonable, and comply with all applicable laws;
  • be for reasons related to the business of Ipeco and the specific individuals involved;
  • where hospitality is given, be capable of being approved and personally reclaimed in accordance with the appropriate business expenses policies and procedures;
  • be recorded in the Register if its approximate value is likely to exceed £50.

Any hospitality offered, given or received shall be within reasonable financial limits and shall never be lavish or extravagant. Where the financial value is likely to exceed £100 per person, it should be authorised in advance by a Director.

10. Prohibited Conduct

The following is absolutely prohibited under this Policy, either by you, or someone acting on your behalf:

  • making unofficial payments to Public Officials in order to obtain or facilitate obtaining any permission, permit or stamp – particularly in connection with importing or exporting goods;
  • giving, promising to give, or offering a payment, gift or hospitality to a Public Official or their agent with a view to expediting a routine procedure;
  • in the case of Employees, appointing any Partner to act on behalf of or otherwise in relation to Ipeco who you know or have good reason to believe has engaged in any corrupt or unlawful conduct including any offences under the Act;
  • paying any third party for the purposes of being a ‘fixer’ to open doors and make connections for Ipeco overseas with the intention of acting unethically, improperly, or other than in accordance with standard market practice in the United Kingdom;
  • accepting a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
  • giving, promising to give, or offering payment, gifts or hospitality with the expectation or hope that a business advantage will be received or to reward the provision of a business advantage;
  • threatening to retaliate against another person who refuses to commit an offence under the Act or who has raised concerns under this Policy; and
  • engaging in any actions that may lead to a breach of this Policy or of the Act.

Facilitation payments: all the above payments are also referred to as ‘facilitation payments’ (‘facilitating’, ‘speed’, ‘backhander’ or ‘grease’ payments) and are payments, usually small cash payments made to low-level officials, as a bribe to secure or expedite the performance of a routine or necessary action. Facilitation payments by Employees are strictly prohibited.

The only facilitation payment exception is if your life is in danger or if the facilitation payment is expressly permitted by the law of the country in which it is paid. If a facilitation payment is made under such circumstances, it must be reported as soor: as is possible to the Finance Director in order that it can be recorded.

11. Due Diligence – Suppliers and Business Partners

The prohibition against offering, providing, authorising, requesting or receiving bribes includes bribes which are given or received by any Partners acting on Ipeco’s behalf or otherwise providing any services to Ipeco. Ipeco can be prosecuted for the actions of these Partners.
In addition to what is set out elsewhere in this Policy, Ipeco implements, so far as is practicable, procedures to prevent Partners from engaging in bribery. The framework for doing this is set out below.
When arranging new contracts for service with a potential Partner, the relevant Manager should ensure that adequate measures are taken to assess the relevant Partner’s anti-bribery policies so as to ensure that they adequately cover and protect the business relationship which is being entered into. When dealing with a Partner in a High Risk Country (see list below) all relevant divisions and locations of Ipeco must consult with the Finance Director in relation to appropriate anti bribery compliance measures before:

  • appointing or otherwise engaging with a new Partner;
  • entering into a business partnership with a Partner
  • appointing a Partner to work on Ipeco’s behalf; or
  • entering into a new contract/or amending the terms of an existing contract with an Partner.

High Risk Countries

Countries in both Transparency International and World Bank high risk lists: Albania, Algeria, Angola, Argentina, Armenia, Azerbaijan, Bangladesh, Belarus, Belize, Benin, Bolivia, Bosnia­ Herzegovina, Brazil, Cameroon, Chad, China, Colombia, Congo, Congo Dem Rep, Cote D’Ivoire, Cuba, Domini can Republic, Ecuador, Egypt, Ethiopia, Gabon, Gambia, Georgia, Ghana, Guatemala, Haiti, Honduras, India, Indonesia, Iran, Iraq, Jamaica, Kazakhstan, Kyrgyz Republic, Kenya, Kyrgyz Republic, Lebanon, Libya, Macedonia, Malawi, Mali, Mexico, Moldova, Mongolia, Morocco, Mozambique, Myanmar, Nepal, Nicaragua, Niger, Nigeria, Palestinian Authority, Pakistan, Panama, Papua New Guinea, Paraguay, Peru, Philippines, Romania, Russia, Senegal,COUNTRIES Sierra Leone, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Thailand, Turkey, Turkmenistan, Uganda, Ukraine, Uzbekistan, Venezuela, Vietnam, Yemen, Zambia, Zimbabwe. Countries in Transparency International high risk list only: Croatia, Eritrea, Latvia, Madagascar, Poland, Saudi Arabia, Serbia and Montenegro, Slovakia. Countries in World Bank list only: Afghanistan, Bulgaria, Burkina Faso, Burundi, Cambodia, Central African Republic, Comoros, Djibouti, El Salvador, Equatorial Guinea, Guinea, Guinea-Bissau, Guyana, Jordan, Kiribati, North Korea, Laos, Lesotho, Liberia, Macao, Marshall Islands, Micronesia, Rwanda, Samoa, Sao Tome and Principe, Solomon Islands, Somalia, Swaziland, East Timor, Togo, Tonga, Trinidad and Tobago, VanuatuThere is a significant risk of bribery when dealing with suppliers, customers or other Partners in a High Risk Country if:

the services being provided involve work being undertaken, directly or indirectly on Ipeco’s behalf, in any High Risk Country; or

• the services involve Partners paying fees, taxes or payments on behalf of Ipeco in relation to services provided or received in a High Risk Country; or

• the services involve Partners obtaining official documents, permits, passes, visas, permissions or agreement from public officials or agencies; or

• there are any particular reasons to suspect that the risk of corruption or bribery is higher than normal.

In addition to the High Risk Countries if an individual has any specific reason to suspect a risk of bribery in any country outside of those listed in the High Risk Country table, caution is advised and any transaction should be discussed with the Finance Director prior to agreements or transactions being made.

The Finance Director will advise on the level of due diligence required and the form of any anti-bribery clauses required in relation to an agreement or contract. Any due diligence must be completed before:

  • the contract with a Partner is signed or renewed;
  • the Partner does any work; or
  • the partnership undertakes any activities.

If the negotiating Manager in Ipeco and the Finance Director cannot agree on whether due diligence is required or the required level or content of the due diligence to be undertaken cannot be agreed upon, then the matter must be referred for determination to the Board for final scrutiny.

12.Public Officials

Specific rules apply to dealing with Public Officials. A Public Official includes:

a. any officer, employee or representative of, or any person otherwise acting in an official capacity for or on behalf of, a government authority;
b. any employee of a government-owned or government-controlled entity;
c. a legislative, administrative or judicial official, regardless of whether elected or appointed;
d. an officer of, or individual who holds a position in, a political party;
e. a candidate for political office;
f. a person who otherwise exercises a public function for or on behalf of any country; and
g. an employee or representative of any public international organization, such as the United Nations.

In practice, this is likely to include civil servants, inspectors, members of a political party, employees of a state university, employees of state-owned or controlled businesses (such as banks, airlines or telecom companies), judges, Customs and Immigration officials, ambassadors and embassy staff, and law enforcement personnel. This is not an exhaustive list.

It is important to note that Public Officials may include, among other things, any employees or others acting on behalf of government-owned or government-controlled entities. A bribe in this context can also include influencing a Public Official to do something which is within the scope of their public duties or which they may otherwise have done in any event.

13. Donations

Ipeco does not make contributions to political parties. Ipeco only makes charitable donations that are legal and ethical under local laws and practices. No donation should be made in the Ipeco name, under any circumstance, without the prior approval of the Chief Executive Officer.

14. What happens if you don’t comply?

For Employees:
Any act of bribery, in whatever form, is unacceptable both in accordance with Ipeco business ethics, and with UK law (including, without limitation, the Act). Ipeco will consider taking disciplinary action against anyone who fails to comply with this Policy up to and including dismissal. Failure to comply with this Policy may also leave Employees open to criminal prosecution under the Act. Offences under the Act can result in a fine and/or imprisonment up to a maximum of 10 years.

For Ipeco:
A breach of this Policy by an Employee or Business Partner could result in Ipeco breaching the Act. An offence under the Act can result in the business being given an unlimited fine and is likely to result in negative publicity and serious damage to the reputation, goodwill and business of Ipeco.

For Partners:
The business relationship with Partners which violate this Policy and/or the Act will be terminated.

15. Concerns

All Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure as to whether a particular circumstance constitutes bribery or corruption, or if you have any other queries in relation to this Policy, these should be raised immediately with your Team Leader, Supervisor or Manager. It is the responsibility of Team Leaders, Supervisors and Managers to ensure that they are available to listen, provide guidance and/or act upon any concerns raised regarding the ethical conduct of, or situations facing, Employees. However, should you feel unable to speak to your immediate superior, you must raise your concerns with another person within your management structure, or with Ipeco’s Human Resources Department. If you are reporting a legitimate misconduct in good faith, you will be fully supported by Ipeco.

16. Protection from bribery

Employees and Associated who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes concerned of repercussions. We aim to encourage openness and will support anyone who raises a genuine concern in good faith under this Policy, even if they turn out to be mistaken.
We are committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, harassment, victimisation or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Ipeco’s Human Resources Department promptly.

17. Who is responsible for the Policy?

The Board has overall responsibility for ensuring this Policy complies with Ipeco’s legal and ethical obligations, and that all those under Ipeco’s control or who act for or otherwise on behalf of Ipeco comply with it.
Ipeco’s Finance Director has responsibility for keeping this Policy up to date and for responding to any queries from Team Leaders, Supervisors and Managers (and, where relevant, from Employees) on the application of this Policy.

The management of Ipeco (that is, its Team Leaders, Supervisors and Managers) has responsibility for the day-to­ day implementation of this Policy and for monitoring its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. The Policy shall be subject to regular review to ensure that it is effective and up to date.
All Employees are responsible individually and collectively for the success of this Policy and to ensure that they use it to make disclosures. If an Employee is of the opinion that the Policy could be improved, then such comments, suggestions and queries should be raised with a Team Leader, Supervisor or Manager.

18. Summary of the UK Bribery Act 2010

The Bribery Act creates four different offenses:

  • a general offence of actively offering, promising or paying a bribe with the intention of obtaining the improper performance of a relevant function or activity;
  • a general offence of requesting, agreeing to receive, or accepting a bribe with the intention of obtaining the improper performance of a relevant function or activity;
  • a separate offence of directly or indirectly bribing of a foreign public official where that official is not permitted or required by the written law of their state to be so influenced (please note that customary practices and tolerance are not deemed to be acceptable); and
  • an offence (under section 7 of the Act) of failure by a commercial organisation to prevent a bribe being paid or received by those acting on its behalf where they intend to obtain or retain business or a business advantage for the commercial organisation unless there are adequate procedures in place.

Jurisdictional Reach:
The Act has extra-territorial reach both for UK companies/persons operating abroad and for overseas companies with a presence in the UK. This means that a UK person, situated outside of the UK, is still subject to UK laws and is still prosecutable by such laws, as well as any applicable laws of the country they are in.

A UK Company can commit an offence under section 7 of the Act for failure to prevent bribery if an employee, subsidiary, agent, service provider or any other associated person of or to that UK Company bribes another person anywhere in the world to obtain or retain business or a business advantage.

A foreign subsidiary or sister Company of a UK Company may cause the parent Company to become liable under section 7 of the Act when the subsidiar y or sister Company commits an act of bribery in the context of performing services for, or for the ultimate benefit of, the UK parent or sister Company.

Should you wish to know more detail about The Bribery Act 2010, you can access it via the following link: legislation .gov.uk/ukpga/2010/23/contents

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