Anti-Bribery and Corruption Policy

Introduction

At RWB Group UK, we are committed to conducting business with integrity, transparency, and in compliance with applicable laws and regulations. This Anti-Bribery and Corruption Policy outlines our commitment to preventing bribery and corruption in all aspects of our operations, both domestically and internationally. We firmly believe that bribery and corruption erode trust, harm economies, and undermine fair competition. We expect all employees, contractors, suppliers, and business partners to uphold the highest ethical standards and comply with this policy.

Policy Statement

1. RWB Group UK has a zero-tolerance approach to bribery and corruption, both within our organization and in relation to our business activities.
2. We are committed to complying with all applicable laws and regulations related to anti-bribery and corruption, including the UK Bribery Act 2010 and other relevant legislation.
3. We strictly prohibit all forms of bribery, including offering, giving, receiving, soliciting, or accepting bribes, whether directly or indirectly, in any form.
4. This policy applies to all employees, contractors, suppliers, and business partners who act on behalf of RWB Group UK or are associated with our operations.

Definitions

1. Bribery: Bribery refers to the offering, giving, receiving, or soliciting of anything of value, either directly or indirectly, to improperly influence the actions or decisions of individuals in a position of trust.
2. Corrupt Practices: Corrupt practices include any dishonest or unethical behaviour aimed at gaining personal or business advantages through abuse of power, deception, or fraudulent activities.

Responsibilities

1. Senior Management: The senior management team at RWB Group UK is responsible for implementing and maintaining effective anti-bribery and corruption measures. They will provide leadership, allocate necessary resources, and ensure that this policy is communicated and understood throughout the organization.
2. Employees: All employees have a responsibility to familiarize themselves with this policy, comply with its principles, and report any concerns or suspicions regarding potential bribery or corruption incidents to the designated point of contact.
3. Contractors, Suppliers, and Business Partners: We expect our contractors, suppliers, and business partners to adhere to the same anti-bribery and corruption principles outlined in this policy. We will engage with them to assess their compliance with anti-bribery laws and encourage them to implement effective measures to prevent bribery and corruption within their own operations.

Guidelines and Procedures

1. Gifts, Hospitality, and Entertainment: Acceptance or offering of gifts, hospitality, or entertainment should be in line with our Gifts and Hospitality Policy and applicable laws and regulations. Gifts and hospitality should never be used as a means to influence or gain improper advantage.
2. Due Diligence: We will conduct due diligence on employees, contractors, suppliers, and business partners to assess their integrity, reputation, and compliance with anti-bribery and corruption laws. This may include background checks, reference checks, and ongoing monitoring.
3. Financial Controls: We will maintain robust financial controls to ensure transparency and accountability in all financial transactions. Payments should be properly authorized, accurately recorded, and supported by legitimate documentation.
4. Reporting and Whistleblowing: We maintain a confidential reporting mechanism that allows employees, contractors, suppliers, and other stakeholders to report any concerns or suspicions regarding potential bribery or corruption. Reports can be made without fear of retaliation, and appropriate actions will be taken based on the findings.
5. Training and Awareness: We will provide training and awareness programs to our employees, contractors, suppliers, and business partners to ensure they understand the risks and consequences of bribery and corruption. Training will cover relevant laws, policies, procedures, and ethical decision-making.

Consequences of Non-Compliance

1. Violation of this Anti-Bribery and Corruption Policy may result in disciplinary action, up to and including termination of employment or contract. Legal and regulatory consequences may also apply.
2. Any employee found guilty of bribery or corruption may be subject to legal proceedings, which can lead to fines, imprisonment, or both.

Monitoring and Review

1. We will regularly monitor and review the effectiveness of this policy and associated procedures to ensure compliance with legal requirements and best practices.
2. Internal audits and risk assessments will be conducted to identify and mitigate bribery and corruption risks within our operations and supply chains.

Date: 6^th March 2023

Signed: Managing Director