Anti-Bribery Policy

Axil Integrated Services (the ‘company’) is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines Axil’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The company will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.

This policy applies to all employees and officers of the company, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the company (“associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, the company is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of Axil.

The company may also face criminal liability for unlawful actions taken by its employees or associated persons under the Bribery Act 2010. All employees and associated persons are required to familiarise themselves and comply with this policy, including any future updates that may be issued from time to time by the company.

This policy covers

• the main areas of liability under the Bribery Act 2010;
• the responsibilities of employees and associated persons acting for, or on behalf of, the organisation; and
• the consequences of any breaches of this policy.

The organisation is committed to complying with the Bribery Act 2010 in its business activities in the UK and overseas.

Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered or requested with the:

• intention of inducing or rewarding improper performance of a function or activity; or
• knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.
• A relevant function or activity includes public, state or business activities or any activity performed in the course of a person’s employment, or on behalf of another organisation or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

A criminal offence will be committed under the Bribery Act 2010 if:

• an employee or associated person acting for, or on behalf of, the organisation
• an employee or associated person acting for, or on behalf of, the organisation offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of their duties (where local law does not permit or require such influence); and
• the organisation does not have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons.

All employees and associated persons are required to comply with this policy, in accordance with the Bribery Act 2010.

The company prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be made to ensure that a person or organisation improperly performs duties or functions to gain any commercial, contractual or regulatory advantage for Axil in either obtaining or maintaining business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Employees and, where applicable, associated persons, are required to take particular care to ensure that all records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers and public officials.

Due diligence should be undertaken by employees and associated persons prior to entering into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative.

Employees and associated persons are required to keep accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered.

Axil prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to government officials for carrying out or speeding up routine procedures. They are more common overseas. Facilitation payments are distinct from an official, publicly available fast-track process. Facilitation payments, or offers of such payments, will constitute a criminal offence by both the individual concerned and the organisation under the Bribery Act 2010, even where such payments are made or requested overseas. Employees and associated persons are required to act with greater vigilance when dealing with government procedures overseas.

Procedure

Where a public official has requested a payment, employees or associated persons should ask for further details of the purpose and nature of the payment in writing. If the public official refuses to give these, this should be reported immediately.

If the public official provides written details, Axil will consider the nature of the payment. Local legal advice may be sought by the organisation.

If it is concluded that the payment is a legitimate fee, for example part of a genuine fast-track process, or is permitted locally, the company will authorise the employee to make the payment.

The organisation will seek the assistance of the relevant employee in its investigation and may determine that the matter should be referred to the prosecution authorities.

Principle

The organisation permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:

• for the purpose of establishing or maintaining good business relationships;
• to improve the image and reputation of the organisation; or
• to present the company services effectively;

provided that it is:

• arranged in good faith; and
• not offered, promised or accepted to secure an advantage or any of its employees or associated persons or to influence the impartiality of the recipient

The company will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure.

This principle applies to employees and associated persons, whether based in the UK.

Charitable and political donations

The company considers that charitable giving can form part of its wider commitment and responsibility to the community. The company supports a number of charities periodically. The company may also support fundraising events involving employees.