Anti-Corruption & Bribery Policy

Introduction

Bribery is an offence. Caldey Corporate Finance Ltd prohibits any form of bribery. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business relationships. We require complete compliance from everyone connected with our business at all times.

Any employee or consultant who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

Definition of ‘Bribery’

Bribery means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract and any other advantage or benefit. ‘Bribery’ includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are prohibited, specifically anyone within and/or associated with Caldey Corporate Finance Ltd must not give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return or to reward business received. Employees and/or Consultants engaged with/by Caldey Corporate Finance must not accept any offer from a third party when it is either known or suspected it is made with the expectation that Caldey Corporate Finance will provide a business advantage for them or anyone else. Furthermore, no offer of or any payment can be made (which sometimes could be referred to as a ‘facilitation payment’), to a government official in any country to facilitate or speed up a routine or necessary procedure.

No retaliation or threat will be made against any person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption within the company.

Suspicion

If we suspect that an act of bribery or attempted bribery has taken place, an investigation will be instigated and carried out, in line with our procedures. For employees, this could include being suspended during the investigation process; for third parties this may be a temporary suspension of services during an investigation process. Where appropriate, action will be taken which may result in dismissal from the company, or the cessation of a business arrangement an individual or company.

Reporting

If an employee or a person working on behalf of the company suspects that an act of bribery or attempted bribery has taken place, even if that person is not personally involved, it is expected that this will be reported to the Managing Director of Caldey Corporate Finance Ltd. You may be asked for a written account of events.

Employees are reminded of the Company’s ‘Whistleblowing Policy.

Gifts and Hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation or marketing our products and services when nothing is expected in return. This does not constitute bribery where it is proportionate and recorded properly.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from the Managing Director.

Similarly, no gift or offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from the Managing Director.

Record Keeping

It is the responsibility of the individual to declare and keep a written record of all hospitality or gifts given or received. All expense claims relating to hospitality, gifts or payments to third parties must be submitted in accordance with the company procedure and record the reason for expenditure.

All accounts, invoices and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept ‘off-book’ to facilitate or conceal improper payments.

As the law is continually changing regarding this matter, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.