Greosn Anti-bribery and Corruption Policy

Our Policy

Greosn is committed to conducting business in an honest and ethical manner. It 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, wherever it operates, and implementing and enforcing effective systems to counter bribery.

It is not acceptable for any Greosn employee (or someone on their behalf) to:

•        give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given

•        give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome

•        accept a payment, gift or hospitality from a third party that they know or suspect is offered with the expectation that it will provide a business advantage for them or anyone else in return

•        accept hospitality from a third party that is unduly lavish or extravagant under the circumstances

•        offer or accept a gift to or from government officials or representatives, or politicians or political parties without the prior approval of the Chief Executive Officer

•        threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy

•        engage in any other activity that might lead to a breach of this policy.

Scope

This policy applies to all growing companies within the Greosn Group, their sites and locations across the UK and to permanent and temporary/seasonal employees. It does not apply to Pro-Force employees and agency workers. It does not form part of an employee’s contract of employment and may be amended at any time. Greosn may also vary the procedure at their discretion.

Responsibility

It is the responsibility of the directors of each business in the group to review, agree and implement this policy.

Policy Principles

Greosn has adopted six policy principles:

•        procedures are proportionate

•        there is top-level commitment

•        an assessment is carried out (e.g., when dealing with companies in overseas countries)

•        due diligence checks are in place

•        there is clear communication of our policy and procedures

•        the policy is monitored and reviewed to keep pace with any changes in risk

The law

The Bribery Act 2010 which sets out the offences of bribing another person, being bribed, bribing a foreign public official and failing to prevent bribery. The Act has extraterritorial effect which means that Greosn can be prosecuted in the UK regardless of where in the world bribery occurs.

•        The Foreign Corrupt Practices Act 1977 which prohibits the giving or offering of money, gifts, or anything “of value” to a foreign government official to obtain or retain business and requires businesses to maintain adequate accounting procedures.

•        Local laws in jurisdictions around the world which are aimed at preventing bribery and corruption. It is the responsibility of employees to familiarise themselves with and comply with all local Anti-bribery laws applicable to their business conduct.

What is Corruption?

Corruption is the abuse of entrusted power for private gain. Bribery is a form of corruption.

What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to improperly gain a commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:

•        giving or offering a bribe

•        receiving or requesting a bribe; or

•        bribing a foreign public official

•        the company may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to employees) for its business benefit

What is and what is NOT acceptable

There are 4 areas covered by this policy:

1.  Gifts and hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from third parties unless otherwise specifically stated. The following principles apply to any gift or hospitality:

•        must not be made with the intention of improperly influencing a third party or employee to obtain or retain business or a business advantage or provide a reward for obtaining or retaining business

•        must comply with local law in all relevant countries

•        must be given in the name of the organisation, not in an individual’s name

•        must not include cash or a cash equivalent

•        must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift

•        must be pre-authorised and given openly, not secretly

The company appreciates that the practice of giving business gifts varies between countries and

regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country.

This policy prohibits neither normal and appropriate hospitality, nor the giving and receiving of gifts (such as Christmas presents as a thank you for business done, or ceremonial gifts at special occasions) of a reasonable value and are proportionate to the reasons for the gift.

2.  Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

3.  Political Contributions

We do not make donations, whether in cash, kind or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage

4.  Charitable donations and sponsorship

The company only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices, and which are in accordance with the company’s internal policies and procedures.

How to raise a concern

It is important that Greosn employees report any suspicions of bribery or corrupt activities to enable the company to investigate and take appropriate action. Greosn employees are encouraged to raise concerns at the earliest stage possible.

If there is any doubt as to whether a certain action or behaviour can be considered bribery or corruption, Greosn colleagues should speak to their manager or a director for clarification.

In event that a GREOSN employee does not feel comfortable to raise with their manager or a director, they can raise a confidential complaint via the independent third party whistleblowing helpline. See the Whistleblowing Policy for details.

Protection

Individuals who refuse to accept or offer a bribe, or who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. Greosn encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Greosn are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or

potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.