Anti-Bribery Policy

The Bribery Act 2010 came into force on 1 July 2011 and it is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery.

This policy applies to all individuals working at all levels and grades, including senior managers, directors, colleagues (whether permanent, fixed-term or temporary), consultants, contractors, and any other persons providing services to Exel Contracts.

What is a Bribe?

A bribe is a financial or other advantage offered or given:

• to anyone to persuade them to or reward them for performing their duties improperly or;
• to any public official with the intention of influencing the official in the performance of his duties.

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all Colleagues must comply strictly with Exel Contracts Ethics in respect of gifts and hospitality. We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of his duties

Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Kickbacks are typically payments made in return for a business favour or advantage. All colleagues must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

Raising Concerns

Colleagues will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No colleague will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken. If a colleague has a concern they wish to raise, they should contact the Director, or, if there is a conflict, the Managing Director.