Anti-Bribery Policy

This policy sets out our policy in relation to bribery and confirms our commitment to compliance with our legal obligations under the Bribery Act 2010.

The policy applies to all employees and to all people or businesses who carry out work or perform services on behalf of the company.

We believe in carrying out business fairly, honestly and openly and expect all employees, partners, agents and contractors to adopt a high standard of business ethics. All directors and senior managers are fully committed to preventing bribery being committed by any employee, person or business who carries out work or performs services on behalf of the company.

Chamberlain Doors Ltd have a zero tolerance of bribery and corruption. We will not permit or condone any form of bribery regardless of whether it takes place directly or through third parties. The policy also extends to the prohibition of bribes which are intended to benefit an employee’s family, friends, associates or acquaintances.

The company prohibits the following:

• The offering, the giving, the solicitation or acceptance of any bribe, whether cash or other inducement to or from any person or company wherever they are situated and whether they are a public official or body or private person or company by any individual employee, agent or other person or body acting on the company’s behalf in order to gain any commercial or contractual advantage for the company in a way which is unethical

OR

• In order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connection with the individual.
• Bribery can lead to heavy fines against the company as well as personal liability for directors, senior managers and individuals who are directly or indirectly involved.
• Disciplinary action will be taken against any employee who is directly or indirectly involved in bribery.
• Consideration will also be given to the termination of any contract with any partner, agent or contractor involved in bribery or which fails to have in place adequate procedures designed to prevent its employees, partners, agents and contractors from committing bribery on its behalf.
• If you suspect that you or someone else has been offered a bribe, you should either inform your Line Manager or, if you suspect that your Line Manager may be involved in bribery, a Senior Manager or Director.
• Employees should note and comply with the following which support our policy of preventing bribery:-

1. Entertainment , Gift & Hospitality Policy
   This applies to any gift or hospitality which you may be offered by a third party in connection with, or as a result of your employment. No gift or corporate hospitality should ever be given or accepted if it is intended to secure or reward the grant of a contract or other business advantage.
2. Procurement Policy
   All contracts for goods and services must be in accordance with our usual procurement procedures
3. Expenses
   All expenses claims must be made, and authorised, in accordance with our usual expenses procedures.

Whistle Blowing

The above policy is in accordance with the Public Interest Disclosure Act 1998 which provides protection against victimisation or dismissal for workers who blow the whistle on criminal behaviour, bribery, or other wrongdoing.

We trust that we can reply on your support and commitment.

K W Diggle, Managing Director

Issued September 2020

For and on behalf of Chamberlain Doors Ltd