Legal

Anti-Bribery Policy

Our commitment to ethical business practices and compliance with anti-corruption legislation.

Zagosa Ltd | Effective: 30/06/2021

1. Purpose

1.1 Zagosa Ltd 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.

1.2 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, 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.

2. Bribery

2.1 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.

2.2 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.

2.3 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.

3. Consequences of Bribery

3.1 Anyone or any organisation found guilty of bribery under the Act may face fines and/or prison terms.

3.2 For employees of the Company, failure to comply with this Policy and/or with the Act may result in disciplinary action which may include dismissal, and criminal penalties under the Act which may result in a fine and/or imprisonment for up to 10 years.

3.3 For the Company, any breach of this Policy by any employee or business associate may result in the Company being subject to fines and suffering negative publicity.

4. Responsibility for Compliance and Scope of Policy

4.1 This Policy applies to all employees, agents, contractors, subcontractors, consultants, business partners and any other parties associated with the Company and/or any of its suppliers and sub-contractors.

4.2 All persons to whom this Policy applies are required to read, understand and comply with it.

4.3 The directors of the Company are responsible for ensuring that this Policy is properly implemented and monitored throughout the organisation.

5. Gifts and Hospitality

5.1 The Company does not prohibit the giving and receiving of reasonable and proportionate gifts and hospitality where such gifts or hospitality are not intended to induce improper conduct and are not given in exchange for any business advantage.

5.2 All gifts and hospitality received by employees must be declared to a director of the Company.

5.3 Gifts of cash or cash equivalents should never be given or received.

6. Reporting and Whistleblowing

6.1 Any employee who suspects that a breach of this Policy has occurred, or is likely to occur, must report their concerns to a director of the Company as soon as possible.

6.2 The Company is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or as a result of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place.

7. Contact

Email: data@zagosa.com

Telephone: +44 3333 394043

Post: Zagosa Ltd, Albion Works, Queens Drive, Swadlincote, Derbyshire, DE11 0EG