Stokers A5 Handbook Policies APR24

ANTI-BRIBERY POLICY

GIFTS In general, Stokers does not believe it is appropriate for employees to accept gifts from customers, clients, suppliers or any other person or organisation with which the Company has (or might have) business connections. This is because it is important to ensure that no employee acts in a way that is inconsistent with the Company’s objectives or with the integrity of the business by accepting a gift in circumstances where it could influence, or be seen to influence, that employee’s business actions or decisions. Any employee who receives a gift of any kind from an existing or potential business contact must disclose the fact of the gift, its nature and the identity of the sender to their line manager. If the gift is anything other than a small token of appreciation, having no substantial financial value (for example flowers or a bottle of wine), the employee will be required to return the gift to the sender, thanking them for the gift but explaining that it is the Company’s policy that employees should not receive gifts. In cases where the employee’s line manager agrees that the gift was sent to the employee as a token of gratitude for work carried out to a particularly high standard or for an exceptional level of service given, the employee may, at the line manager’s discretion, be permitted to retain the gift. Therefore small gifts, genuinely given as a token of appreciation or gratitude will be acceptable, provided that the employee properly declares the gift in line with this policy and provided that the employee does not subsequently treat the person who sent the gift any more favourably than they would treat other customers, clients, suppliers etc. If an employee wishes to provide a gift to a customer, client, supplier or other business contact, they must seek prior written approval from their line manager and a Director of the Company, with details of the gift, the intended recipients, the reasons for the gift and the business objective. Gifts will only be authorised in limited circumstances and will be subject to a cap of £50.00 per recipient.

Bribery is defined as “giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so”. The Bribery Act 2010 makes it a criminal offence to: • Offer, promise or give a bribe to another person; • Request, agree to receive or accept a bribe; • Bribe a foreign public official to obtain or retain business or advantage for business; • Fail to prevent bribery on behalf of a commercial organisation. Stokers adopts a zero tolerance approach to bribery. Any behaviour which constitutes or may constitute an act of bribery (and thus, an offence under the Bribery Act 2010) is strictly prohibited. Employees should not offer or accept a gift or other benefit in circumstances where it could influence, or be seen to influence their impartiality, or affect their business actions or decisions. BUSINESS ENTERTAINMENT Stokers recognises that corporate entertainment can provide opportunities to strengthen business relationships, enhance the Company’s reputation and deepen prospective or existing clients or customers’ or suppliers’ understanding of the business. Any entertainment booked for clients or customers, prospective clients or customers, suppliers or other business contacts must be approved in advance by the employee’s line manager and a Director of the Company. The employee should submit and clarify: • Details of the individuals to be invited; • The name of the company or organisation the invitees represent; • The nature of the entertainment, including date and location; and • The business reasons for the entertainment. Stokers will only approve business entertainment proposals that demonstrate a clear business objective and that are appropriate for the nature of the business relationship. The Company will not approve business entertainment where it considers the entertainment is extravagant, where a conflict of interest may arise or where it could be perceived that undue influence or a particular business benefit is being sought (for example, prior to a tendering exercise).

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