Anti-Bribery Policy

Anti-bribery policy

Armaflo Ltd (“The Company”) values its reputation for ethical behaviour and for financial probity and reliability. We recognise that over and above the commission of any crime, any involvement in bribery will also reflect adversely on our image and reputation. Our aim therefore is to limit our exposure to bribery by:

  • • setting out a clear anti-bribery policy,
  • • establishing and implementing anti-bribery procedures as appropriate,
  • • communicating this policy and any relevant procedures to employees and to others who will perform services for the Company,
  • • undertaking appropriate due diligence measures before engaging others to represent the Company in their business dealings,
  • • monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures that are in place.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

What is bribery?

“Bribe” means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. “Bribery” includes offering, promising, giving, accepting or seeking a bribe.
The Company strictly prohibits all forms of bribery, including the offering, giving, solicitation or acceptance of any bribe:

  • • to or from any person or company wherever they are situated and whether they are a public or governmental official or body or private person or company (including to facilitate or speed up a routine or necessary procedure),
  • • by any individual employee, agent or other person or body acting on behalf of the Company,
  • • in order to gain or expectation of any commercial, contractual or regulatory advantage for the Company,
  • • in order to gain or expectation of any personal advantage (monetary or otherwise) for the individual or anyone connected with the individual.

This policy prohibits any inducement that results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action that may not be solely in the interests of the Company or of the person or body employing them or whom they represent.

You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Gifts and Hospitality

This policy is not meant to prohibit:

  • • normal and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services; or
  • • the giving of a gift on a festival or at another special time,

provided they are customary in a particular market, are proportionate and are properly recorded. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Training and Communication

Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and as appropriate thereafter.

How to raise a concern

Inevitably, decisions as to what is acceptable may not always be easy. If you are in any doubt as to whether a potential act constitutes bribery, or if you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, the matter should be referred to a Director.
The prevention, detection and reporting of bribery is the responsibility of all employees and the Company is committed to:

  • • encouraging employees to be vigilant and to report any suspicion of bribery,
  • • providing employees with suitable channels of communication and ensuring that sensitive information is treated appropriately,
  • • investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution,
  • • taking disciplinary action against any individual(s) involved in bribery.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Any suspicion of bribery should be reported in confidence to a Director, who has overall responsibility for bribery prevention.

Signed: Terry Harmer

Date: 23/08/2023

Position: Managing Director

Review: 23/08/2024