Anti-Bribery Policy

Introduction

The Cloud One Group Limited aims to ensure all its business affairs are conducted in an ethical and honest manner. The Company has a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships and implementing and enforcing effective systems to counter bribery.

The Bribery Act 2010 is important to all employees of Cloud One because if an employee is deemed to be guilty of an offence under this legislation, it could lead to summary dismissal for gross misconduct under the Company’s disciplinary procedure. If the Company were also found to have acted negligently in respect of trying to prevent bribery in the organisation, then the company and its Directors could be subject to criminal sanctions including unlimited fines and imprisonment.

Policy

This policy aims to increase your awareness of the Company’s position on preventing and prohibiting bribery in accordance with the Bribery Act 2010.

This policy applies to all employees of Cloud One as well as agency workers, temporary workers, contractors, consultants and any third party with whom you may come into contact with during the course of your work. Third parties may therefore include current and potential clients, customers, suppliers, distributors, advisers, business contacts and government and public bodies.

What is a Bribe?

A bribe is an inducement or reward offered, promised or provided in order to gain a commercial, contractual, regulatory or personal advantage.

The Company prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe.

Receiving Gifts and Corporate Hospitality

The Company recognises that gifts and hospitality can be an important part of developing relationships with business contacts. Gifts are usually given as a mark of appreciation. You must make a Director aware of any gifts or hospitality offered to you.

Hospitality is a way of building upon existing relationships or creating new ones. It may include entertaining, meals, receptions, tickets to entertainment, social or sports events with the purpose of initiating or developing relationships with business contacts, for example. Please remember that if you accept such forms of hospitality, the host should always be present, otherwise it is a gift.

Accepting lavish, extravagant or repeated hospitality could easily be misinterpreted by third parties. Please review the appropriateness of the invitation with a Director before accepting.

In general, the Company believes that receiving a gift or corporate hospitality up to the value of £25 (VAT inclusive) is a proportionate means of achieving our legitimate aim to build and maintain good relationships with customers, suppliers and business contacts. However, a Director will decide whether it is appropriate to accept the gift or hospitality. If you believe that the gift or hospitality may exceed the limits outlined above, you will need to complete an authorisation form.

Providing Gifts and Corporate Hospitality

In order to protect yourself and the Company from allegations of bribery you must complete an authorisation form for any gift or hospitality totalling more than £25 (VAT inclusive). This form must be authorised by a Director prior to any gift being purchased or hospitality arranged.

In some cases, it may be acceptable to provide a gift to a customer or business contact. Before doing this, please give consideration as to how this may be perceived by the recipient. For example, you should consider whether there may be any possible suggestion of undue influence upon a customer or business contact before making a gift and also whether the provision or acceptance of the gift may contravene the recipient’s own internal policies. There may also be tax implications if the value of the gift is over a certain amount.

The Company will authorise reasonable and proportionate hospitality events which are arranged in good faith as part of our normal client and business relationship development practices. However, if you provide hospitality which is lavish, provided frequently, especially to the same individuals, or leaves the recipient in a position of obligation, this may lead us to question this further with you to determine if you have exceeded the scope of the policy.

Contract Negotiations

Those employees responsible for negotiating supplier contracts must always ensure that they negotiate the contract in a way that is in the best interests of Cloud One and not for any personal gain. Any personal advantage must be declared openly as part of the supplier proposal and must not be a factor in deciding which supplier to award the contract to.

Reporting Allegations of Bribery

Cloud One is committed to acting in a professional manner and promoting an anti-corruption culture within its business. Should you believe that a fellow employee is giving or receiving bribes then you must notify a Director as soon as possible so that these allegations can be investigated further. If you are asked by a client or supplier for gifts, hospitality or anything else which you believe would constitute a bribe under the policy definition then you must report the incident to one of the Directors immediately.

All allegations of bribery will be investigated thoroughly with action taken as appropriate. This may lead to disciplinary action for employees involved, up to and including summary dismissal for serious cases deemed to be gross misconduct. All relevant employees will be required to co-operate in any investigation into possible or suspected bribery.

Policy Responsibilities

The Managing Director has overall responsibility for ensuring this policy complies with all requirements of the Bribery Act 2010.

Every manager will be responsible for ensuring that their employees are adhering to this policy and will monitor and review all hospitality bills and gift or hospitality offers from suppliers to ensure compliance.

The Finance Department will be responsible for conducting audit checks on all expenses, with particular attention paid to authorisation for gifts and hospitality to ensure these are offered and received in accordance with the word and spirit of this policy.

Managers should report all gifts and hospitality offered and accepted by themselves or employees to the Finance Department who will keep accurate, detailed and up to date records, including those not requiring to be authorised.

All employees are responsible for ensuring that they adhere to the requirements of this policy and report any suspicions to a director immediately.