NEWTECNIC ANTI-BRIBERY AND CORRUPTION POLICY

INTRODUCTION

This policy sets out Newtecnic's anti-bribery and corruption rules and explains what is expected of all Newtecnic personnel and associated persons. We ask all staff to act according to the spirit and the values represented by these policies in all activities undertaken as part of Newtecnic.

LEGISLATION

The UK's Bribery Act 2010 (the ‘Act’) reformed the criminal law providing a new, modern and comprehensive scheme of bribery offences that enable courts and prosecutors to respond more effectively to bribery at home or abroad.

Key elements of the Act are:

• Two general offences which cover the offering, promising or giving of an advantage, and requesting, agreeing to receive or accepting of an advantage.

• A discrete offence of bribery of a foreign public official.

• An offence of failure by a commercial organisation to prevent a bribe being paid for or on its behalf (it will be a defence if the organisation has adequate procedures in place to prevent bribery).

More information is available at https://www.gov.uk/government/publications/bribery-act-2010-guidance

PENALTIES FOR ENGAGING IN BRIBERY AND CORRUPTION

As befits a serious criminal offence, the penalties for engaging in bribery or corruption are severe. Individuals and companies can face punitive fines and even imprisonment. As noted above, in the UK, the legislation incorporates a specific criminal offence of a company failing to prevent bribery committed on its behalf. We take this responsibility very seriously and this is why we want to be associated only with those whose standards match our own.

A conviction for a bribery or corruption related offence would have severe penalties for our reputation. A damaged reputation could lead to us being excluded from tender lists or overlooked when bidding; loss of business; or a decrease in stakeholder confidence, all of which could have severe financial consequences for our business.

UNDERSTANDING AND RECOGNISING BRIBERY AND CORRUPTION

Bribery and corruption can occur in many forms; so understanding them and recognising when they might occur is a key step in guarding against them.

Bribery is when a person offers, promises or gives a financial (or other) advantage to another person with the intention of inducing or rewarding that person to act improperly (active bribery), or when a person requests, agrees to receive or accepts a financial (or other) advantage to act improperly (passive bribery).

Corruption is any form of illegal, dishonest or bad behaviour, especially by people in positions of power and responsibility.