This anti-bribery and corruption policy set out BibbEgan Group (BIBBEGAN ’s) responsibilities in regard to observing and upholding our zero-tolerance position on bribery and corruption. It also acts as a source of information and guidance for those working for BIBBEGAN GROUP OF COMPANIES LIMITED, helping them to recognise and deal with bribery and corruption issues.

BibbEgan Group Limited is committed to conducting business in an ethical and honest manner and implementing and enforcing systems that ensure bribery is prevented. BIBBEGAN are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.

BibbEgan will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regard to our conduct both at home and abroad.

BibbEgan recognises that bribery and corruption are punishable by up to ten years of imprisonment and/or a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

This anti-bribery policy applies to all employees (temporary or permanent), or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees. The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

In the context of this policy, third-party refers to any individual or organisation our company meets and works with, including potential clients, consultants, contractors, suppliers, distributors, business contacts, agents, advisers, and government and public. Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

The definition of bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s management.

James Bibbey Managing Director for and on behalf of BibbEgan