RJ McLeod

Anti-Bribery and Corruption Policy

RJ McLeod is committed to the highest standards of ethical conduct and integrity in its business activities. This policy sets out RJ McLeod’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 RJ McLeod Anti-Bribery and Corruption Policy (‘the Policy’) sets out the key Anti- Bribery and Corruption principles which RJ McLeod is committed to.

Policy Scope

All RJ McLeod 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 or our subsidiaries and associates operate. The Policy extends to RJ McLeod having proportionate procedures to ensure that all service providers (including subcontractors and suppliers) comply with RJ McLeod’s anti-bribery and corruption policies. Where RJ McLeod has a minority interest we will encourage the application of the Policy amongst our business partners including joint venture partners. It is essential that RJ McLeod conduct 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 RJ McLeod.

Anti-Bribery and Corruption Policy

RJ McLeod 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.

RJ McLeod 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 RJ McLeod 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 RJ McLeod 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 in one of the following ways:

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

Implementation, Monitoring and Compliance

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

Further information and training on the Act and what it means for RJ McLeod 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 RJ McLeod 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

Last reviewed 27th October 2015

RJ McLeod