Anti-bribery & Corruption Policy

The Bribery Act 2010 came into force on 1 July 2011 and creates a framework of five criminal offences:

• Giving, promising, and offering of a bribe
• Agreeing to receive or accept a bribe
• Bribing a foreign official
• Failure of commercial organisations to prevent bribery
• A senior officer of a commercial organisation consenting to or conniving in an act of bribery

Includability will conduct 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 business dealings and relationships, as well as implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010, which applies to conduct both in the UK and abroad.

Scope

All Includability employees and others acting on behalf of Includability must comply with this Anti-Bribery and Corruption Policy and it extends to all business dealings and transactions in the UK and in all countries in which we operate. Any breach of the policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned. This could constitute gross misconduct for which an offending employee may be dismissed without notice.

Gifts & Hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, any gift or hospitality:

• Must not be made with the intention of improperly influencing a Third Party or Worker 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;
• Must comply with local law in all relevant countries;
• Must be given in the name of the organisation, not in an individual’s name;
• Must not include cash or a cash equivalent;
• Must be appropriate in the circumstances;
• Must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift; and
• Must be given openly, not secretly.

It is not acceptable for an employee (or someone on their behalf) to:

• Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or Includability will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
• Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
• Accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
• Accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by EllisKnight International in return; Threaten or retaliate against another member of staff who has refused to commit a bribery offence or who has raised concerns under this policy; or
• Engage in any activity that might lead to a breach of this policy.
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Charitable donations and sponsorship

Includability only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with our internal policies and procedures.

Record keeping

Includability maintains appropriate financial records and has appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

Responsibilities and raising concerns

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

Employees are required to notify the business owners as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Further Information and Guidance

This policy sets out the key principles which Includability must adhere to. The Bribery Act 2010 can be viewed at: http://www.legislation.gov.uk