Anti-Bribery and Corruption Policy

RJ McLeod (Contractors) Ltd is committed to the highest standards of ethical conduct and integrity in its business activities. This policy sets out the Company’s position on preventing and prohibiting bribery and corruption in accordance with the Bribery Act 2010 (‘the Act’).

The Act came into force on 1 July 2011 and created a framework of four criminal offences:

• giving, promising, and offering of a bribe;
• agreeing to receive or accept a bribe;
• bribing a foreign official; and
• failure of commercial organisations to prevent bribery.

The Act can be viewed using the following link: http://www.legislation.gov.uk/ukpga/2010/23/contents7view-plain

Policy Objective

The Company’s Anti-Bribery and Corruption Policy (‘the Policy’) sets out the key Anti- Bribery and Corruption principles which Company is committed to.

Policy Scope

All Company employees, subcontractors and suppliers must comply with the Policy and it extends to all of our majority owned business dealings and transactions in the UK and in all countries in which RJ McLeod (Contractors) Ltd or our subsidiaries and associates operate. The Policy extends to the Company having proportionate procedures to ensure that all service providers (including subcontractors and suppliers) comply with the Company’s anti-bribery and corruption policies. Where the Company has a minority interest we will encourage the application of the Policy amongst our business partners including joint venture partners. It is essential that the Company conducts an effective process of due diligence prior to entering into significant business relationships and that we keep a record of this process.

Any breach of the Policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of the Company.

Anti-Bribery and Corruption Policy

The Company does not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings, both with public officials and people in the private sector. Ethical behaviour is in the long term interests of our Company.

The Company is committed to the following key Anti-Bribery and Corruption principles:

• We will carry out business fairly, honestly and openly
• We will not give or offer any money, gift, hospitality or other advantage to any person carrying out a business or public role, or to a third party associated with that person, to get them to do something improper
• We will not give or offer any money, gift, hospitality or other advantages to any foreign public official with the intention of influencing them to our business advantage
• We will not use intermediaries or subcontractors for the purpose of committing acts of bribery
• Any employee found to be in breach of these principles will face disciplinary action
• We do not allow employees to accept money, gifts, hospitality and other advantages from business associates, actual or potential suppliers, or service providers which are intended to influence a business decision or transaction in some improper way
• No employee will suffer demotion, penalty, or other adverse consequence for refusing to pay bribes, even if it may result in Company losing business
• We will avoid doing business with others who do not commit to conducting business without bribery
• We are committed to a programme to counter the risk of Company being involved in bribery. We will have adequate procedures in place to ensure that all employees understand the implications of the Act and our procedures. We will have appropriate mechanisms in place to record any problems.

Any concerns relating to a breach of the Policy should be reported to one of the following:

• Agent
• Contracts Manager
• Company Secretary
• North Director
• Joint Managing Director

Implementation, Monitoring and Compliance

RJ McLeod (Contractors) Ltd will conduct risk assessments across its businesses on a regular basis and where relevant will identify employees or officers of the Company who are in positions where they may be exposed to bribery.

Further information and training on the Act and what it means for the Company will be issued to these bribery risk areas identified in the risk assessment. This training will be mandatory for those individuals identified in these risk areas.

General guidance will be cascaded through senior management and line managers and will be made available to all employees.

The Directors will monitor the adequacy of this Policy and associated processes and procedures on an annual basis.

Further information and guidance

This policy set outs the key principles which the Company must adhere to. Further relevant information and guidance about this policy can be found in the UK Ministry of Justice website:

• http://www.iustice.gov.uk/guidance/making-and-reviewing-the-law/bribery.htm

BG CLARK

Joint Managing Director

Issued: June 2023