Purpose

This policy sets out the responsibility of Elcometer Ltd as a corporate entity (including all subsidiary businesses wherever located), and all employees of Elcometer and its subsidiaries (hereafter referred to as the “Group”) in observing and upholding the Group’s position on bribery and corruption.

It also provides information and guidance to all employees of the Group on how to recognise and deal with bribery and corruption issues.

Policy Statement

It is the Group’s policy to conduct all business in an honest and ethical manner. A zero-tolerance approach to bribery and corruption is taken by the Group and it is committed to acting professionally, fairly and with integrity in all dealings wherever it operates. The Group is committed to implementing and enforcing effective systems to counter bribery.

Legislation

The Bribery Act 2010 became part of UK law on 1^st July 2011.

Bribery is now punishable for both individuals (up to ten years’ imprisonment and unlimited fines) and corporate entities (unlimited fines). In addition, it is now an offence for corporate entities to fail to prevent bribery.

This applies to all UK businesses and any other business, wherever registered, if it carries on any business in the UK or is managed by people with a UK connection. As such this applies as much to Elcometer Ltd’s overseas subsidiaries as it does to the UK business.

Who is covered by the policy?

This policy applies to all employees (whether permanent, fixed-term or temporary), consultants, contractors, agency staff or any other person providing services to the Group (collectively referred to as “workers” hereafter).

What is bribery?

A bribe is a financial or other advantage offered or given to a person in order to gain a commercial, contractual or personal advantage. (For the avoidance of doubt, this does not include discounting of product).

Under the Bribery Act 2010, it is an offence to bribe another or to receive a bribe. In addition, however, no money needs to have changed hands for people to be caught under the Act – a person can be guilty of an offence if they offer/promise to pay or request/agree to receive a financial or other advantage.

Gifts and Hospitality

The Group will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence any commercial or public official in the performance of their duties. The Group will not make contributions of any kind to political parties and no charitable donations will be made for the purpose of gaining any commercial advantage.

This policy does not prohibit the giving and receiving of promotional gifts of low value and normal and appropriate hospitality. As stated in the Elcometer Ltd Staff Handbook however, the offer of gifts or entertainment in excess of ?50 must not be accepted without the prior approval of a Director.

Gifts or hospitality given or received must be reasonable and justifiable. The following points are intended as guidelines in this respect:

• Gifts or hospitality are not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• it is not an unlawful gift;
• it is given in the name of the business and not in an individuals name;
• it does not include cash or a cash equivalent (such as gift certificates or vouchers);
• it is appropriate in the circumstances (for example, small gifts given at Christmas time);
• taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
• it is given openly, not secretly.

Record-keeping

The Group will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

Workers must ensure all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the expenses policy in force at each business and must specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties such as customers, suppliers and business contacts must be prepared and maintained with strict accuracy and completeness.  No accounts must be kept "off-book" to facilitate or conceal improper payments.

Workers responsibilities

All workers must ensure that they read, understand and comply with this policy at all times.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Group or under the Group’s control.  All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

Raising Concerns

Workers are encouraged to raise concerns to a Company Director about any issue or suspicion of malpractice at the earliest possible stage.

No worker will suffer any detrimental treatment as a result of either refusing to take part in bribery or as a result of raising genuine concerns about bribery, even if these turn out to be mistaken. (Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern).

Monitoring

The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

Internal control systems and procedures will be subject to regular audits to provide assurance that these are effective in countering bribery.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.