The purpose of this policy is to:

1. set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and :
2. Provide information and guidance to those working for us on how to recognize and deal with bribery and-corruption issues.

We have identified that certain of our activities create particular risks for our organization, in particular:

1. Recruitment
2. Receipt of gifts and donations
3. Purchasing
4. Sub contracting

To address these risks, we have taken the following steps:

1. Implemented an anti-bribery and corruption policy;
2. Undertaken a risk assessment exercise, which will be subject to on-going review;
3. Undertaken a training programme to all concern departments

EMPLOYEES RESPONSIBILITIES

1. You must ensure that you read, understand and comply with this policy.
2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3. You must notify your manager and/or the Compliance Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you tha a gift or payment is required to secure their business

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct

WHAT TO DO IF YOU ARE A VICTIM OF BRIBERY OR CORRUPTION

It is important that you tell the Manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

PROTECTION

Workers/Employees, who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim 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.

Potential risk scenarios: "red flags"

The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under anti-bribery and anti-corruption.

If you encounter any of these red flags while working for us, you must report them promptly to your manager:

1. A third party offering a commission or cash payment before supplying the raw material.
2. A third party offers an unexpected commission for their faulty service.
3. A third party offers an unexpected commission for accepting their goods to be returned.
4. A third party offers lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services.
5. A third-party request that a payment is made to "overlook" potential legal violations.
6. You receive an invoice from a third party that appears to be non-standard or customized.
7. A third party insists on the use of side letters or refuses to put terms agreed in writing.
8. You are offered an unusually generous gift or offered lavish hospitality by a third party.

Disciplinary actions regarding bribery or corruption

Particulars	Procedure	Action
Complaint about commission by supplier or any contractor	Investigation by owners about complaint. After verification of such complaint.	Warning letter to warn not to be done in future.
Complaint about passing important business secrets to competitor	Investigation by owners about complaint. After verification of such complaint.	Final warning to warn not to be done in future.
Recurring Complaints about passing important business secrets to competitor or taking commission on purchase	Investigation by owners about complaint. After verification of such complaint.	Direct dismissal without any notice.