Anti Bribery Policy

Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that HiSpec Electrical Products Limited conducts its business in a socially responsible manner.

Policy Statement

HiSpec Electrical Products Limited takes a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate. We will uphold all laws relevant to countering bribery and corruption, including the UK Bribery Act 2010. We are committed to operating and delivering goods and services to our customers in compliance with those laws and ensure that our Colleagues and Third Parties do not engage in or facilitate bribery or corruption.

Scope

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.

Policy Principles

• Act with integrity at all times.
• Comply with all applicable laws.
• Avoid conflicts of interest.
• Not offer or give bribes or improper inducements to business partners either directly or indirectly (through third parties).
• Not ask for or accept bribes or other improper inducements from anyone, including business partners.
• Not offer or receive gifts or hospitality where the intention might be seen as influencing business decisions.
• Not solicit or receive any advantage to encourage an abuse of influence in order to obtain favourable decisions from Government Officials.
• Establish a clear business rationale for instructing any vendors, contractors, agents, representatives, and other service providers.
• Perform (and record) robust due diligence on any vendors, contractors, agents, representatives, and other service providers.
• Be sensitive in all dealings with public officials or government staff.
• Not induce, encourage, or facilitate someone else to break the law.
• Report attempted bribes or suspicions of corrupt behaviour.
• Maintain full and accurate records of all payments.

Bribes

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. Suppliers may offer discounts, rebates or other commercial terms of sale. These are not bribes if they are commercially justified and properly documented.

Gifts and Hospitality

• Which could be regarded as illegal or improper, or which violates the recipient’s policies.
• Unless approved in writing by the managing director.

• If it is in cash.
• If there is any suggestion that a return favour will be expected or implied.

Facilitation Payments and Kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

Political Contributions

We do not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. This ensures that we do not engage in any form of political corruption.

Charitable Contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in-kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery.

Responsibilities

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

Reporting

Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your manager or the Head of Compliance and Sustainability.

Monitoring and Review

The Head of Compliance and Sustainability will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible.