Ignitec Ltd Anti-Bribery and Corruption Policy

1. Introduction

Ignitec Ltd is committed to conducting its business in an ethical and honest manner and has zero tolerance for bribery and corruption. This policy applies to all employees of Ignitec Ltd and is designed to help identify, prevent, and eliminate instances of bribery and corruption in all areas of our business.

2. Definition of Bribery

Bribery refers to the act of offering, giving, receiving, or soliciting something of value as a means to influence the actions of an individual or company in the discharge of legal or public duties. A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantages.

3. Policy

All employees of Ignitec Ltd must not offer, give, request, or accept any bribe, whether in the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other advantage or benefit. This prohibition applies to all business dealings in all sectors including but not limited to mining, telecommunications, banking and financial services, healthcare, manufacturing, construction, agriculture, forestry, fishing, professional services, technology, government, defence, and energy in the UK or in any other country in which we do business.

4. Gifts and Hospitality

Ignitec Ltd permits normal and appropriate hospitality and giving/receiving gifts under certain circumstances. The following principles apply to the acceptance of gifts and hospitality:

• Gifts must be of a nominal or notional value. Typically, a gift should not be accepted if the cumulative value from any one organisation or individual exceeds £200 in any 12-month period or £100 for any one gift.
• The gift must be given for an appropriate reason and at an appropriate time (e.g. not in advance of the issuing of an opinion or determination, or in advance of the award of a contract).
• The gift must be of a “one-off” or irregular nature (i.e. that could not be viewed as a regular source of income by HMRC for personal taxation purposes).
• Reciprocal gifting is not encouraged. However, there may be circumstances where the failure to give a gift would give offence, such as during an official visit by foreign officials whose custom is to give and/or receive a token of friendship or respect. In these circumstances, authority from the Chief Executive must be sought.
• Members and staff should not encourage business contacts to provide hospitality to them, or indirectly to other colleagues, friends, or relatives.
• Offers of hospitality should be reported to the Managing Director. Some examples of hospitality which should be refused include payments for lunch or dinner and tickets to sporting or leisure events.
• It may be considered appropriate to accept a working lunch, dinner or attendance at an annual stakeholder event, where it is not lavish in nature, not a frequent occurrence, and there is no suspicion of a conflict of interest.
• All accepted or declined gifts and hospitality should be fully recorded in the Gifts and Hospitality Register (see Appendix), which will be published on Ignitec Ltd’s website.

5. Roles and Responsibilities

The Managing Director of Ignitec Ltd is responsible for implementing this policy, monitoring its use and effectiveness, and dealing with any queries about it.

6. Record Keeping

Ignitec Ltd will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, understanding that gifts and acts of hospitality are subject to managerial review.

7. Reporting

If any employee suspects or knows of any instance of bribery or corruption related to Ignitec Ltd, they must report it immediately through our dedicated whistleblowing system, Trusty Report. Ignitec Ltd is committed to ensuring that those who report instances of bribery or corruption will not face any retaliation.

8. Disciplinary Actions

Ignitec Ltd will fully investigate any instances of alleged or suspected bribery. Employees found to be in violation of this policy may face disciplinary action, up to and including dismissal. Ignitec Ltd also reserves the right to terminate a contractual relationship with any employee if they breach this anti-bribery policy.

9. Training

Ignitec Ltd will provide annual training and refresher sessions to all employees to help them recognize and prevent bribery and corruption activities. Employees will be encouraged to seek advice from the Managing Director when in doubt about any issues related to this policy.

10. Review and Updates

Ignitec Ltd will review and update this policy annually to reflect changes to law, reputational requirements, and changes in our business activities.