14\/8\/2020<\/p>
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1.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Print Clever is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations and other requirements which govern the conduct of our operations.<\/p>
1.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (\u201cthe Act\u201d) and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.<\/p>
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2.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Bribery is defined as the giving or promising of a financial or other advantage to another party where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage is in itself improper conduct.<\/p>
2.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Bribery is also deemed to take place if any party requests or agrees to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly, where the acceptance of that advantage is in itself improper conduct, or where that party acts improperly in anticipation of such advantage.<\/p>
2.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Bribery of a foreign official is defined as the giving or promising of a financial or other advantage which is intended to influence the official in order to obtain business or an advantage in the conduct of business unless the foreign official is required or permitted by law to be influenced by such advantage.<\/p>
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3.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Anyone or any organisation found guilty of bribery under the Act may face fines and\/or prison terms.\u00a0 In addition, high legal costs and adverse publicity are likely to result from any breach of the Act.<\/p>
3.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 For employees of the Company, failure to comply with this Policy and\/or with the Act may result in:<\/p>
3.2.1\u00a0\u00a0\u00a0\u00a0\u00a0 disciplinary action which may include dismissal; and<\/p>
3.2.2\u00a0\u00a0\u00a0\u00a0\u00a0 criminal penalties under the Act which may result in a fine and\/or imprisonment for up to 10 years.<\/p>
3.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 For the Company, any breach of this Policy by any employee or business associate may result in:<\/p>
3.3.1\u00a0\u00a0\u00a0\u00a0\u00a0 the Company being deemed to be in breach of the Act;<\/p>
3.3.2\u00a0\u00a0\u00a0\u00a0\u00a0 the Company being subject to fines; and<\/p>
3.3.3\u00a0\u00a0\u00a0\u00a0\u00a0 the Company suffering negative publicity and further associated damage as a result of such breach.<\/p>
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4.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 This Policy applies to all employees, agents, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and bodies corporate) associated with the Company or any of its subsidiaries.<\/p>
4.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 It is the responsibility of all of the abovementioned parties to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with the Company\u2019s Whistleblowing Policy or as otherwise stated in this Policy, as appropriate.<\/p>
4.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 No party described in section 4.1 may:<\/p>
4.3.1\u00a0\u00a0\u00a0\u00a0\u00a0 give or promise any financial or other advantage to another party (or use a third party to do the same) on the Company\u2019s behalf where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage will in itself constitute improper conduct;<\/p>
4.3.2\u00a0\u00a0\u00a0\u00a0\u00a0 request or agree to receive any financial or other advantage from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.<\/p>
4.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Parties described in section 4.1 must:<\/p>
4.4.1\u00a0\u00a0\u00a0\u00a0\u00a0 be aware and alert at all times of all bribery risks as described in this Policy and in particular as set out in section 9 below;<\/p>
4.4.2\u00a0\u00a0\u00a0\u00a0\u00a0 exercise due diligence at all times when dealing with third parties on behalf of the Company; and<\/p>
4.4.3\u00a0\u00a0\u00a0\u00a0\u00a0 report any and all concerns relating to bribery to Tony Acres or, in the case of non-employees, their normal point of contact within the Company, or otherwise in accordance with the Company\u2019s Whistleblowing Policy.<\/p>
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5.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 A facilitation payment is defined as a small payment made to officials in order to ensure or speed up the performance of routine or necessary functions.<\/p>
5.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Facilitation payments constitute bribes and, subject to section 5.3, may not be made at any time irrespective of prevailing business customs in certain territories.<\/p>
5.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Facilitation or similar payments may be made in limited circumstances where your life is in danger but under no other circumstances.\u00a0 Any payment so made must be reported to Tony Acres - Operation Director as soon as is reasonably possible and practicable.<\/p>
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6.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Gifts and hospitality remain a legitimate part of conducting business and should be provided only in compliance with the Company\u2019s Gifts and Hospitality Policy.<\/p>
6.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Gifts and hospitality can, when excessive, constitute a bribe and\/or a conflict of interest.\u00a0 Care and due diligence should be exercised at all times when giving or receiving any form of gift or hospitality on behalf of the Company.<\/p>
6.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The following general principles apply:<\/p>
6.3.1\u00a0\u00a0\u00a0\u00a0\u00a0 Gifts and hospitality may neither be given nor received as rewards, inducements or encouragement for preferential treatment or inappropriate or dishonest conduct.<\/p>
6.3.2\u00a0\u00a0\u00a0\u00a0\u00a0 Neither gifts nor hospitality should be actively sought or encouraged from any party, nor should the impression be given that the award of any business, custom, contract or similar will be in any way conditional on gifts or hospitality.<\/p>
6.3.3\u00a0\u00a0\u00a0\u00a0\u00a0 Cash should be neither given nor received as a gift under any circumstances.<\/p>
6.3.4\u00a0\u00a0\u00a0\u00a0\u00a0 Gifts and hospitality to or from relevant parties should be generally avoided at the time of contracts being tendered or awarded.<\/p>
6.3.5\u00a0\u00a0\u00a0\u00a0\u00a0 The value of all gifts and hospitality, whether given or received, should be proportionate to the matter to which they relate and should not be unusually high or generous when compared to prevailing practices in our industry or sector.<\/p>
6.3.6\u00a0\u00a0\u00a0\u00a0\u00a0 Certain gifts which would otherwise be in breach of this Policy and\/or the Hospitality and Gifts Policy may be accepted if refusal would cause significant and\/or cultural offence, however the Company will donate any gifts accepted for such reasons to a charity Tony Acres - Operation Director choosing.<\/p>
6.3.7\u00a0\u00a0\u00a0\u00a0\u00a0 All gifts and hospitality, whether given or received, must be recorded in the Hospitality & Gifts Register.<\/p>
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7.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Charitable donations are permitted only to registered (non-profit) charities.\u00a0 No charitable donations may be given to any organisation which is not a registered charity.<\/p>
7.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 All charitable donations must be fully recorded in an Excel spreadsheet managed<\/p>
7.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Proof of receipt of all charitable donations must be obtained from the recipient organisation.<\/p>
7.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Under no circumstances may charitable donations be made in cash.<\/p>
7.5\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 No charitable donation may be made at the request of any party where that donation may result in improper conduct.<\/p>
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8.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.<\/p>
8.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Employees and other associated parties are free to make personal donations provided such payments are not purported to be made on behalf of the Company and are not made to obtain any form of advantage in any business transaction.<\/p>
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The following issues should be considered with care in any and all transactions, dealings with officials, and other business matters concerning third parties:<\/p>
9.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Territorial risks, particularly the prevalence of bribery and corruption in a particular country;<\/p>
9.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Cross-border payments, particularly those involving territories falling under section 9.1;<\/p>
9.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Requests for cash payment, payment through intermediaries or other unusual methods of payment;<\/p>
9.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Activities requiring the Company and \/ or any associated party to obtain permits or other forms of official authorisation;<\/p>
9.5\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Transactions involving the import or export of goods;<\/p>"},"borderRadius":{"id":104610379,"value":"#{text.border.radius}"},"textColor":{"id":104610380,"value":"#{text.color}"},"backgroundColour":{"id":104610381,"value":"#0000"},"truncateHeight":{"id":104610382,"value":null},"template":{"id":104610383,"value":"text"},"padding":{"id":104610384,"value":"6"},"fullWidth":{"id":104610385,"value":"0"},"fullBackgroundColor":{"id":104610386,"value":"#{text.fullBackground.color}"},"published":{"id":104610387,"value":"1"},"conditions":{"id":104610388,"value":"[]"}}}],"properties":{"title":{"id":104610340,"value":"Anti-Bribery"},"isStorePage":{"id":104610341,"value":"1"},"ogImage":{"id":104610345,"value":"https:\/\/images.podos.io\/pgl1z37ylq82nwho11b47fsunjufdizybeh4ouixtpuetvl6.webp.webp?w=1200&h=auto"}},"labels":[],"published":1,"sitemap":1,"divisionId":388371,"edited":true,"keyPhraseCampaignId":null}